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In certain circumstance the Court may estimate various
expenses. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d
Cir. 1930). Section 274(d), however, imposes strict
substantiation requirements for expenses relating to travel and
in this regard supersedes the Cohan doctrine. See Sanford v.
Commissioner, 50 T.C. 823, 827 (1968), affd. 412 F.2d 201 (2d
Cir. 1969). To obtain a deduction for travel, a taxpayer must
substantiate “by adequate records or by sufficient evidence
corroborating * * * [his] own statement” the amount of the
expense and the time and place of the travel. Sec. 274(d).
Petitioner, as noted, presented no evidence to satisfy section
274(d).4 Accordingly, as to this issue, we hold for respondent.
With respect to the Schedule C loss, petitioner conceded
that issue in the stipulation of facts.
In closing, we observe that to the end petitioner has sought
to depose Mr. Evans, an Appeals officer with whom he met in
attempts to settle this matter. Putting aside the untimeliness
and other deficiencies with respect to petitioner’s application,
we cannot fathom what information Mr. Evans could have possessed
that would have shed any material light on the issues properly
before this Court. The evidence concerning substantiation under
section 274(d) is under petitioner’s control. Furthermore, any
4 We also note that there is a problem of hearsay with
respect to the expenses of petitioner’s wife.
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