- 16 -
that extent. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d
Cir. 1930). However, in order for the Court to estimate the
amount of an expense, we must have some basis upon which an
estimate may be made. Vanicek v. Commissioner, 85 T.C. 731, 743
(1985). Without such a basis, any allowance would amount to
unguided largesse. Williams v. United States, 245 F.2d 559, 560
(5th Cir. 1957).
In the case of certain expenses, section 274(d) overrides
the so-called Cohan doctrine. Sanford v. Commissioner, 50 T.C.
823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969);
sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014
(Nov. 6, 1985). Specifically, section 274(d) provides that no
deduction is allowable either for travel, including meals while
away from home, or with respect to listed property as defined in
section 280F(d)(4), unless the deduction is substantiated in
accordance with the strict substantiation requirements of section
274(d) and the regulations promulgated thereunder. Included in
the definition of listed property in section 280F(d)(4) is any
passenger automobile, any computer or peripheral equipment, and
any cellular telephone or other similar telecommunications
equipment. Sec. 280F(d)(4)(A)(i), (iv), (v).
Thus, under section 274(d), no deduction is allowable for
expenses incurred either for travel or in respect of listed
property such as a passenger automobile, a computer or peripheral
equipment, or a cellular telephone or other similar
telecommunications equipment, on the basis of any approximation
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