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Commissioner, 50 T.C. 823, 827-828 (1968), affd. per curiam 412
F.2d 201 (2d Cir. 1969).
Nearly all of the claimed job search expenses are travel
expenses subject to the strict substantiation requirements
imposed by section 274(d). Under section 274(d), no deduction
may be allowed for expenses incurred for travel, or certain other
expenses, on the basis of any approximation or the unsupported
testimony of the taxpayer. Section 274(d) imposes strict
substantiation requirements to which taxpayers must strictly
adhere. Thus, section 274(d) specifically proscribes deductions
for travel expenses in the absence of adequate records, or of
sufficient evidence corroborating the taxpayer’s own statement.
At a minimum, the taxpayer must substantiate: (1) The amount of
such expense; (2) the time and place such expense was incurred;
and (3) the business purpose for which such expense was incurred.
Petitioners claim that they kept adequate records and
receipts to substantiate their claimed expenses, but that such
records and receipts were allegedly destroyed by water damage.
Petitioners offered and the Court received into evidence an
expense log. Petitioners’ expense log was based on their
recollection of the expenses and travel dates, but no receipts or
documents were used in its preparation. The total expense
claimed in the log was $11,073. We do not accept this log as
reliable evidence because it was prepared approximately 2 months
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