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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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