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search expenses consisted of the cost of travel in her own
automobile to potential employers’ places of business. This
portion of her job search expenses is supported by the work search
record with respect to three interviews and by the mileage log.
In the case of travel expenses, entertainment expenses, and
expenses paid or incurred with respect to certain listed property,
section 274 overrides the Cohan doctrine, discussed previously,
and those expenses are deductible only if the taxpayer meets the
stringent substantiation requirements of section 274(d). Sanford
v. Commissioner, 50 T.C. 823, 827-828 (1968), affd. per curiam 412
F.2d 201 (2d Cir. 1969).
Section 274 contemplates that no deduction may be allowed for
expenses incurred for travel on the basis of any approximation or
the unsupported testimony of the taxpayer. Sec. 1.274-5T(a),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
Section 274(d) specifically proscribes deductions for travel
expenses in the absence of adequate records or of sufficient
evidence corroborating the taxpayer’s own statement. At a
minimum, the taxpayer must substantiate: (1) The amount of such
expense; (2) the time and place such expense was incurred; and (3)
the business purpose for which such expense was incurred.
Mrs. Harrell’s unemployment compensation work search record
constitutes substantiation within the meaning of section 274 with
respect to three job interviews that required travel. The record
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