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incurred, and the business purposes. Sec. 274(d). The
provisions of section 274(d) preclude the allowance of any
estimated amount by this Court as the Court may allow in other
circumstances under Cohan v. Commissioner, supra at 543-544, even
if the Court is convinced the taxpayer incurred such expenses.
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., supra. Respondent, therefore, is sustained on
this issue.
The final issue with respect to petitioner’s Schedule C
self-employment activity is $8,100 deducted as “other expenses”
that respondent disallowed. In a statement attached to the
return, these expenses were listed as accounting, bank charges,
janitorial, laundry and cleaning, a pager, postage, printing,
safety equipment, telephone, tools, and uniforms. The Court is
satisfied that petitioner incurred some of these expenses,
although some of the claimed expenses are listed properties under
section 280F(d)(4), and no amount is allowable as a deduction for
such expenses unless proper substantiation is provided as
required under section 274(d). Petitioners did not substantiate
any of the claimed expenses. The Court is satisfied that
petitioners incurred some expenses that are not subject to the
strict substantiation rules of section 274, and, for such
expenses, the Court allows petitioners a deduction of $2,000.
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