George A. and Christine M. Evan - Page 15

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          being a professor during the years in issue, petitioners are not            
          entitled to deductions for claimed expenses on the basis of a               
          job-hunting or education purpose.                                           
               D.   Substantiation of Expenses                                        
               In any event, petitioners argue that the expenses were                 
          substantiated with adequate records.  We disagree.                          
               Under section 162, a taxpayer may deduct all ordinary and              
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business if the taxpayer maintains                 
          sufficient records to substantiate the expenses.  Secs. 162(a),             
          6001; sec. 1.6001-1(a), Income Tax Regs.  The taxpayer bears the            
          burden of substantiation.  Hradesky v. Commissioner, 65 T.C. 87,            
          90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976).  As a             
          general rule, no deductions are allowed for personal, living, or            
          family expenses.  Sec. 262(a).                                              
               If a taxpayer has established that deductible expenses were            
          incurred but has not established the amount of those expenses, we           
          may estimate the amount allowable (Cohan doctrine).  Cohan v.               
          Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).  There must be           
          evidence in the record, however, that provides a rational basis             
          for our estimate.  Vanicek v. Commissioner, 85 T.C. 731, 742-743            
          (1985).                                                                     
               In the case of travel expenses and expenses paid or incurred           
          with respect to listed property, e.g., passenger automobiles,               
          section 274 overrides the Cohan doctrine, and expenses are                  
          deductible only if the taxpayer meets the section’s stringent               





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