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The first issue for decision is whether petitioner is
entitled to deduct an NOL carryover of $7,367.70. Generally, NOL
carryovers are allowed as deductions under section 172(a).
A taxpayer generally must keep records sufficient to
establish the amounts of the items reported on his Federal income
tax return. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
However, in the event that a taxpayer establishes that a
deductible expense has been paid but is unable to substantiate
the precise amount, we generally may estimate the amount of the
deductible expense bearing heavily against the taxpayer whose
inexactitude in substantiating the amount of the expense is of
his own making. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d
Cir. 1930). We cannot estimate a deductible expense, however,
unless the taxpayer presents evidence sufficient to provide some
basis upon which an estimate may be made. Vanicek v.
Commissioner, 85 T.C. 731, 743 (1985).
Section 274(d) supersedes the Cohan doctrine. Sanford v.
Commissioner, 50 T.C. 823, 827 (1968), affd. 412 F.2d 201 (2d
Cir. 1969). Section 274(d) provides that, unless the taxpayer
complies with certain strict substantiation rules, no deduction
is allowable (1) for traveling expenses, (2) for entertainment
expenses, (3) for expenses for gifts, or (4) with respect to
listed property. Listed property includes passenger automobiles
and other property used as a means of transportation. Sec.
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