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Cohan. See sec. 1.274-5T(c)(2), Temporary Income Tax Regs., 50
Fed. Reg. 46017 (Nov. 6, 1985). Section 274(d) provides that no
deduction shall be allowed with respect to the use of any "listed
property", as defined in section 280F(d)(4), unless the taxpayer
substantiates certain elements. "Listed property" includes any
property used as a means of transportation, and any computer or
peripheral equipment. Sec. 280F(d)(4)(A)(ii), (iv).
For an expense described in the above category, the taxpayer
must substantiate by adequate records or sufficient evidence to
corroborate the taxpayer's own testimony: (1) The amount of the
expenditure or use on the basis of the appropriate measure
(mileage may be used in the case of automobiles); (2) the time
and place of the expenditure or use; and (3) the business purpose
of the expenditure or use.
To meet the adequate records requirements of section 274, a
taxpayer must maintain some form of records and documentary
evidence that in combination are sufficient to establish each
element of an expenditure or use. See sec. 1.274-5T(c)(2),
Temporary Income Tax Regs., supra. A contemporaneous log is not
required, but corroborative evidence to support a taxpayer's
reconstruction of the elements of expenditure or use must have "a
high degree of probative value to elevate such statement" to the
level of credibility of a contemporaneous record. Sec. 1.274-
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