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sufficient to permit verification of income and expenses. See
sec. 1.6001-1(a), Income Tax Regs.
As a general rule, if, in the absence of such records, a
taxpayer provides sufficient evidence that the taxpayer has
incurred a deductible expense, but the taxpayer is unable to
adequately substantiate the amount of the deduction to which he
or she is otherwise entitled, the Court may estimate the amount
of such expense and allow the deduction to that extent. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). However, in
order for the Court to estimate the amount of an expense, we must
have some basis upon which an estimate may be made. Vanicek v.
Commissioner, 85 T.C. 731, 743 (1985). Without such a basis, any
allowance would amount to unguided largesse. Williams v. United
States, 245 F.2d 559, 560 (5th Cir. 1957).
In the case of certain expenses, section 274(d) overrides
the so-called Cohan doctrine. 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., 50 Fed. Reg. 46014
(Nov. 6, 1985). Specifically, and as relevant herein, section
274(d) provides that no deduction is allowable with respect to
listed property as defined in section 280F(d)(4) unless the
deduction is substantiated in accordance with the strict
substantiation requirements of section 274(d) and the regulations
promulgated thereunder. Included in the definition of listed
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