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and from work, as a commuting expense is considered to be
personal and nondeductible. Commissioner v. Flowers, 326 U.S.
465, 473-474 (1946); sec. 1.162-2(e), Income Tax Regs. An
exception to the nondeductibility of commuting expenses involves
situations where the transportation is to and from a temporary
work location. See Rev. Rul. 90-23, 1990-1 C.B. 28, as amplified
and clarified by Rev. Rul. 94-47, 1994-2 C.B. 18, as modified and
superseded by Rev. Rul. 99-7, 1999-1 C.B. 361.
Also, certain business expenses described in section 274(d)
are subject to strict substantiation rules that supersede the
Cohan doctrine. Sanford v. Commissioner, 50 T.C. 823, 827-828
(1968), affd. per curiam 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) applies to: (1) Any traveling expense,
including meals and lodging away from home; (2) entertainment,
amusement, and recreational expenses; or (3) the use of “listed
property”, as defined in section 280F(d), including passenger
automobiles. To deduct such expenses, the taxpayer must
substantiate by adequate records or sufficient evidence to
corroborate the taxpayer’s own testimony: (1) The amount of the
expenditure or use, which includes mileage in the case of
automobiles; (2) the time and place of the travel, entertainment,
or use; (3) its business purpose; and in the case of
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