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estimate, however, must have a reasonable evidentiary basis.
Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). With respect
to certain business expenses, section 274 supersedes the Cohan
doctrine. See sec. 1.274-5T(a), Temporary Income Tax Regs., 50
Fed. Reg. 46014 (Nov. 6, 1985).
Applying more stringent substantiation requirements, section
274(d) disallows deductions for traveling expenses, gifts, and
meals and entertainment, as well as for "listed property", unless
the taxpayer substantiates by adequate records or by sufficient
evidence corroborating the taxpayer's own statement: (1) The
amount of the expense; (2) the time and place of the expense; (3)
the business purpose of the expense; and (4) the business
relationship to the taxpayer of the persons involved in the
expense.
Petitioners' charitable contribution deductions are governed
by section 170. Section 170(a) allows a deduction for any
charitable contribution to or for the use of an organization
described in section 170(c), payment of which is made during the
taxable year and verified under regulations prescribed by the
Secretary. In general, the amount of a charitable contribution
made in property other than money is the fair market value of the
donated property at the time of the contribution. Hewitt v.
Commissioner, 109 T.C. 258, 261 (1997), affd. without published
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