Lee B. Arberg and Melissa A. Quinn - Page 39




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               Furthermore, business expenses described in section 274 are            
          subject to rules of substantiation that supersede the doctrine of           
          Cohan v. Commissioner, supra.  Sanford v. Commissioner, 50 T.C.             
          823, 827-828 (1968), affd. 412 F.2d 201 (2d Cir. 1969); sec.                
          1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov.           
          6, 1985).  Section 274(d) provides that no deduction shall be               
          allowed for, among other things, traveling expenses,                        
          entertainment expenses, gifts, and expenses with respect to                 
          listed property (as defined in section 280F(d)(4) and including             
          passenger automobiles, computer equipment, and cellular                     
          telephones) “unless the taxpayer substantiates by adequate                  
          records or by sufficient evidence corroborating the taxpayer’s              
          own statement”:  (1) The amount of the expenditure or use; (2)              
          the time and place of the expenditure or use, or date and                   
          description of the gift; (3) the business purpose of the                    
          expenditure or use; and (4) in the case of entertainment or                 
          gifts, the business relationship to the taxpayer of the                     
          recipients or persons entertained.  Sec. 274(d).                            
               On this issue, petitioners neither at trial nor on brief               
          offered argument directed towards the deductibility of any of the           
          specific expenses disallowed or recharacterized by respondent.              
          Rather, their contentions seem to be confined to the following              
          generalized paragraph on reply brief:                                       
               Similarly, Respondent repeatedly contends in his Brief                 
               (e.g., at 10, 11) that Petitioners failed to                           






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