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expense but is unable to substantiate the precise amount, the
Court may approximate the amount, bearing heavily if it chooses
against the taxpayer whose inexactitude is of his own making.
Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). The
Court must, however, have evidence sufficient to provide a
rational basis upon which an estimate can be made. Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985).
Section 274(d) imposes more stringent substantiation
requirements for the deduction of traveling, automobile, and
entertainment expenses. Taxpayers must substantiate these items
by adequate records in order to claim deductions, documenting
details such as the amount and place of each separate
expenditure, the property's business and total usage, and the
date and business purpose of the expenditure or use. Sec.
274(d); sec. 1.274-5T(b), Temporary Income Tax Regs., 50 Fed.
Reg. 46014 (Nov. 6, 1985). These strict substantiation
requirements with respect to expenses for travel, meals,
entertainment, and expenses relating to the use of listed
property preclude this Court from using the "Cohan rule" to
estimate the deductible amount of such expenses. Sanford v.
Commissioner, 50 T.C. 823, 827-828 (1968), affd. per curiam 412
F.2d 201 (2d Cir. 1969). Where, however, a taxpayer establishes
that the failure to produce adequate records is due to the loss
of such records through circumstances beyond the taxpayer's
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