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diary, log, statement of expense, trip sheet or similar record,
and/or other documentary evidence, which, in combination, are
sufficient to establish each element of expenditure or use. Sec.
1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017
(Nov. 6, 1985). Each recording of an element of an expenditure
or use must be made at or near the time of the expenditure or
use. Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income Tax Regs., 50
Fed. Reg. 46017 (Nov. 6, 1985). Alternatively, a taxpayer who is
unable to satisfy the adequate records requirement is still
entitled to a deduction for expenses that he can substantiate
with other corroborative evidence. Sec. 1.274-5T(c)(3),
Temporary Income Tax Regs., 50 Fed. Reg. 46020 (Nov. 6, 1985).
Moreover, when section 274(d) applies, as here, this Court cannot
rely on Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930), to
estimate the taxpayer’s expenses. Sanford v. Commissioner, 50
T.C. 823, 827-828 (1968), affd. per curiam 412 F.2d 201 (2d Cir.
1969).
Petitioner had no books of account or other records
concerning his alleged businesses or any evidence of the
expenditures in issue. Petitioner relied on his own testimony.
Petitioner claimed that he found customers for the travel
agents at Sun Trips Travel (Sun Trips), San Jose, California.
Petitioner had no client lists. Petitioner admitted that Sun
Trips did not require him to pick up the tickets. Petitioner
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