(ii) Time and place of travel or entertainment (or use of a facility with respect to entertainment), or date and description of a gift Section 274(d) and this section contemplate that no deduction shall be allowed for any expenditure for travel, entertainment, or a gift unless the taxpayer substantiates the following elements for each such expenditure: (b) Elements of an expenditure-(1) In general. For purposes of this section, the term entertainment means entertainment, amusement, or recreation, and use of a facility therefore and the term expenditure includes expenses and items (including items such as losses and depreciation). Section 274(d) contemplates that no deduction shall be allowed a taxpayer for such expenditures on the basis of such approximations or unsupported testimony of the taxpayer.
The decision held that, where the evidence indicated a taxpayer incurred deductible travel or entertainment expense but the exact amount could not be determined, the court should make a close approximation and not disallow the deduction entirely. This limitation supersedes with respect to any such expenditure the doctrine of Cohan v.
(3) Gifts defined in section 274, unless the taxpayer substantiates such expenditure as provided in paragraph (c) of this section. (2) Any activity which is of a type generally considered to constitute entertainment, amusement, or recreation, or with respect to a facility used in connection with such an activity, including the items specified in section 274(e), or (1) Traveling away from home (including meals and lodging) deductible under section 162 or 212, No deduction shall be allowed for any expenditure with respect to:
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