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sufficient to provide some basis upon which an estimate may be
made. See Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).
Section 274(d) imposes stricter requirements and supersedes
the Cohan doctrine. See Sanford v. Commissioner, 50 T.C. 823,
827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969).
Section 274(d) 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,
see sec. 280F(d)(4), including passenger automobiles, computers
and peripheral equipment, and cellular phones. To meet the
strict substantiation requirements, the taxpayer must
substantiate the amount, time, place, and business purpose of the
expenses. See sec. 274(d); sec. 1.274-5T, Temporary Income Tax
Regs., 50 Fed. Reg. 46006 (Nov. 6, 1985).
An LLC with more than one member is treated as a partnership
for Federal income tax purposes unless the LLC elects otherwise.
See sec. 301.7701-3(b)(1)(i), Proced. & Admin. Regs. The parties
stipulated that Daybreak never filed any "Federal income tax
returns". From this stipulation the Court assumes that Daybreak
filed neither Forms 1065, U.S. Return of Partnership Income, nor
Form 8832, Entity Classification Election. Petitioner merely
filed a Schedule C and claimed a net loss from the activity of
the LLC as though it were a proprietorship. Petitioner, however,
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