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Section 274(d) supersedes the general rule of Cohan v.
Commissioner, supra, and we cannot estimate the taxpayer’s
expenses with respect to certain items. See Sanford v.
Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d
201 (2d Cir. 1969). Section 274(d) imposes strict substantiation
requirements for listed property, travel, entertainment, and meal
expenses. See sec. 1.274-5T(a), Temporary Income Tax Regs., 50
Fed. Reg. 46014 (Nov. 6, 1985). Listed property can include
computers and peripheral equipment. See sec. 280F(d)(4)(iv). To
obtain a deduction for a listed property, travel, or meal
expense, a taxpayer must substantiate by adequate records or
sufficient evidence to corroborate the taxpayer’s own testimony
the amount of the expense, the time and place where it was
incurred, and the business purpose of the expense. See sec.
274(d); sec. 1.274-5T(b), Temporary Income Tax Regs., 50 Fed.
Reg. 46016 (Nov. 6, 1985). If a taxpayer is unable to fulfill
the requirements of section 274(d), he is not entitled to the
deduction.
2. Advertising and Insurance
Petitioner generally testified that he placed advertisements
either in magazines or on the Internet. Petitioner also deducted
amounts for insurance that was likely related to his personal
automobile. He did not provide receipts evidencing the
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