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permitted to make as close an approximation as it can, bearing
heavily against the taxpayer whose inexactitude is of his or her
own making. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.
1930). The estimate must have a reasonable evidentiary basis.
Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). However,
section 274 supersedes the Cohan doctrine, see sec. 1.274-5T(a),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985),
and requires strict substantiation of expenses for travel, meals
and entertainment, and gifts, and with respect to any listed
property as defined in section 280F(d)(4).
A taxpayer is required by section 274(d) to substantiate a
claimed expense by adequate records or by sufficient evidence
corroborating the taxpayer’s own statement establishing the
amount, time, place, and business purpose of the expense. Sec.
274(d). Even if such an expense would otherwise be deductible,
the deduction may still be denied if there is insufficient
substantiation to support it. Sec. 1.274-5T(a), Temporary Income
Tax Regs., supra.
We find petitioner’s testimony in this matter to be
truthful. We agree with petitioner that he has substantiated the
business expenses deducted on Schedule A and that the amounts
have been accepted by respondent. We further agree that a
portion of the expenses should have been reported on Schedule C
instead of Schedule A. However, we do not agree with the
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