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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). Furthermore, section 274(d) supersedes the Cohan
doctrine and prohibits estimating certain expenses. Sanford v.
Commissioner, 50 T.C. 823, 827 (1968), affd. 412 F.2d 201 (2d
Cir. 1969). That section provides that unless the taxpayer
complies with certain strict substantiation rules, no deduction
is allowable (1) for travel 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, computers,
and cell phones or other similar telecommunications equipment.
Sec. 280F(d)(4). To meet the strict substantiation requirements,
the taxpayer must substantiate the amount, time, place, and
business purpose of the expenses. Sec. 274(d); sec. 1.274-5T,
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
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