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to a deduction but does not establish the amount of the
deduction, the Court is allowed to estimate an allowable amount.
Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930). However,
section 274(d) precludes use of the so-called Cohan rule and
provides that no deduction is allowable under section 162 for any
traveling expenses, including meals and lodging while away from
home unless the taxpayer complies with strict substantiation
rules. Sec. 274(d)(1), (4). Particularly, the taxpayer must
substantiate the amount, time, place, and business purpose of the
enumerated types of expenses by adequate records or by sufficient
evidence corroborating his own statement. Sec. 274(d); sec.
1.274-5T(b)(2), (6), (c), Temporary Income Tax Regs., 50 Fed.
Reg. 46014, 46016 (Nov. 6, 1985).
To address circumstances under which it would be
impracticable or overly burdensome to require detailed
documentary evidence, section 274(d) and the regulations
thereunder vest the Secretary with the authority to promulgate
regulations that prescribe alternative methods for substantiating
expenses covered by section 274. Sec. 1.274-5T(j), Temporary
Income Tax Regs., 50 Fed. Reg. 46032 (Nov. 6, 1985). Pursuant to
this authority, the Secretary issued Rev. Proc. 94-77, 1994-2
C.B. 825; Rev. Proc. 96-28, 1996-1 C.B. 686; and Rev. Proc. 96-
64, 1996-2 C.B. 427, in effect for the years 1995, 1996, and
1997, respectively, providing rules under which the amount of
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