George W. Moss and Gwendolyn Arline-Moss - Page 5

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          estimate the amount of such an expense and allow the deduction to           
          that extent.  See Finley v. Commissioner, 255 F.2d 128, 133 (10th           
          Cir. 1958), affg. 27 T.C. 413 (1956);  Cohan v. Commissioner, 39            
          F.2d 540, 543-544 (2d Cir. 1930).  In order for the Court to                
          estimate the amount of an expense, however, there must be some              
          basis upon which an estimate may be made.  Vanicek v.                       
          Commissioner, 85 T.C. 731, 742-743 (1985).  Without such a basis,           
          an allowance would amount to unguided largesse.  Williams v.                
          United States, 245 F.2d 559, 560 (5th Cir. 1957).                           
               With respect to certain business expenses specified in                 
          section 274(d), however, more stringent substantiation                      
          requirements apply.  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 expenses; (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.  The term listed property           
          is defined in section 280(F)(d) and includes cellular phones, and           
          other similar telecommunications equipment, such as pagers.  See            
          sec. 280F(d)(4)(v).                                                         
               The substantiation requirements of section 274(d) are                  
          designed to encourage taxpayers to maintain records, together               






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