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or use, and the business purpose for an expenditure or use. Sec.
274(d); sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed.
Reg. 46016 (Nov. 6, 1985). To substantiate a deduction by means
of adequate records, a taxpayer must maintain an account book,
diary, log, statement of expense, trip sheet or similar record,
and/or other documentary evidence, which, in combination, are
sufficient to establish each element of expenditure or use. Sec.
1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017
(Nov. 6, 1985). Each recording of an element of an expenditure
or use must be made at or near the time of the expenditure or
use. Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income Tax Regs., 50
Fed. Reg. 46017 (Nov. 6, 1985). A taxpayer who is unable to
satisfy the adequate records requirement is still entitled to a
deduction for expenses that he can substantiate with other
corroborative evidence. Sec. 1.274-5T(c)(3), Temporary Income
Tax Regs., 50 Fed. Reg. 46020 (Nov. 6, 1985). When section
274(d) applies, as here, this Court cannot rely on Cohan v.
Commissioner, 39 F.2d 540 (2d Cir. 1930), to estimate the
taxpayer’s expenses. Sanford v. Commissioner, 50 T.C. 823, 827-
828 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969).
Respondent disallowed $3,243 of petitioner’s claimed $6,905
deduction for car and truck expenses. Petitioner submitted a so-
called log listing his travel expenses. We are not required to
accept petitioner’s self-serving statements as gospel. Tokarski
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