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court have been shown to be other than travel between his
residence and court. Therefore, we hold that any parking fees
incurred in connection with such travel constitute nondeductible
commuting expenses. See Anderson v. Commissioner, 60 T.C. 834,
836 (1973).
Even if the parking fees were shown to be associated with
deductible business trips, we agree with respondent that the
deduction of such fees must be denied due to lack of
substantiation. Petitioner failed to produce any receipts or
other evidence that might have corroborated his oral testimony.
Moreover, assuming arguendo that petitioner is not required to
satisfy the substantiation requirements of section 274(d)(1) with
respect to the parking fees, petitioner has failed to provide the
minimal substantiation that would permit us to estimate the
allowable deduction as permitted under Cohan v. Commissioner, 39
F.2d 540, 543-544 (2d Cir. 1930). Even under Cohan, there must
be sufficient evidence in the record to provide a basis upon
which an estimate may be made. Vanicek v. Commissioner, 85 T.C.
731, 742-743 (1985). Here, there is none. Petitioner’s failure
to offer any substantiation that would corroborate his oral
testimony provides an additional basis for sustaining
respondent’s denial of the deduction for the parking fees. See
Allied Marine Sys., Inc. v. Commissioner, T.C. Memo. 1997-101,
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