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sufficient to establish the amounts of the items reported on his
Federal income tax return. Sec. 6001; sec. 1.6001-1(a), (e),
Income Tax Regs. In the event that 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 traveling 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. Sec.
280F(d)(4). To meet the strict substantiation requirements, the
taxpayer must substantiate the amount, time, place, and business
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