taxable year in carrying on a trade or business. Sec. 162(a). A taxpayer, however, is required to maintain records sufficient to establish the amounts of his deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax Regs. When a taxpayer establishes that he paid or incurred a deductible expense but does not establish the amount of the deduction, we may estimate the amount allowable in certain circumstances. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742743 (1985). There must be sufficient evidence in the record, however, to permit us to conclude that a deductible expense was paid or incurred in at least the amount allowed. Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957). In addition to satisfying the criteria for deductibility under section 162, certain categories of expenses must also satisfy the strict substantiation requirements of section 274(d) in order for a deduction to be allowed. We may not use the Cohan doctrine to estimate expenses covered by section 274(d). See 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). To substantiate a deduction pursuant to section 274(d), a taxpayer must maintain adequate records or present corroborative evidence to show the following: (1) The amount of the expense; (2) the time and place of use of the listed property; and (3) the business purpose of the use. Sec. 274(d); sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). When a taxpayer's records have been destroyed or lost due to circumstances beyond his control, he is generally allowed to substantiate his deductions through secondary evidence. Malinowski v. Commissioner, 71 T.C. 1120, 1125 (1979); sec. 1.274-5T(c)(5), Temporary Income Tax Regs., 50 Fed. Reg. 46022 (Nov. 6, 1985). A taxpayer in this type of situation may reconstruct his expenses through other credible evidence. Watson v. Commissioner, T.C. Memo. 1988-29; sec. 1.274-5T(c)(5), Temporary Income Tax Regs., supra. If no other documentation is available, we may, although we are not required to do so, accept credible testimony of a taxpayer to substantiate a deduction. Watson v. Commissioner, supra. Having observed the witnesses' appearance and demeanor at trial, we find them to be honest, forthright, and credible. The drivers who testified at trial provided reasonable estimates of their monthly travel expenses. Beverly James estimated monthly expenses as follows: $52.50 for motels, $12 for showers, $30 for truck parking, $30 for laundry, and $32 for Federal Express charges. These expenses averaged $5.60 per day, using a 28-day month. David Butler estimated monthly expenses as follows: $117 for motels, $50 for showers, $20 for truck parking, $22 for laundry, and $32 for Federal Express charges. These expenses averaged $8.60 per day, using a 28-day month. William Lane estimated monthly expenses as follows: $65 for motels, $60 for showers, $55 for truck parking, $30 for laundry, and $32 for Federal Express charges. These expenses averaged $8.64 per day, using a 28day month. Mr. Lane estimated his expenses for meals at approximately $24-$25 per day. Despite the credible testimony of the witnesses, we find that petitioners did not substantiate the travel expense deductions of their approximately 300 drivers pursuant to strict standards of section 274(d) and the regulations. Petitioners did not establish the amount, time, or place of each separate expenditure for each of the drivers. Sec. 1.274– 5T(b)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). Petitioners did not establish the dates of departure and return for each trip away from home by each driver, or the exact number of days away from home. Sec. 1.274–5T(b)(2)(ii), Temporary Income Tax Regs., supra. Petitioners did not establish the exact destination or locality of travel, as described by name of city or town or other similar designation. Sec. 1.274-5T(b)(2)(iii), Temporary Income Tax Regs., 50 Fed. Reg. 46015 (Nov. 6, 1985). What petitioners did is provide good, reasonable estimates and averages of the expenses that Continental's drivers incurred on the road. While we understand why petitioners made a business decision not to require receipts and records of the drivers' expenses, the regulations under section 274(d) make it clear that estimates and averages are not sufficient to establish travel expenses pursuant to section 274(d). See Sanford v. Commissioner, 50 T.C. at 827 (the Cohan doctrine does not apply to expenses covered by section 274(d)). Furthermore, we note that were we to find that some of the expenses were ordinary business expenses under section 162, petitioners have failed to substantiate meals and other incidental expenses pursuant to section 274(d). Therefore, petitioners fare better with the deemed substantiation of the revenue procedures than by actual substantiation under sections 162 and 274(d). III. Whether Petitioners May Deduct More Than 50 Percent of the Nonmeal Travel Expenses Incurred by Drivers Petitioners argue that "if the Fifth Part of Section 4.02 of Revenue Procedure 94-77 is valid, petitioners are entitled to a downward adjustment in the audit adjustment to Continental's net income for payment of substantial, fully deductible nonmeal travel expenses." Essentially, petitioners seek to deduct an amount of the per diem allowance that is more than 50 percent, but less than 80 percent, by obtaining a full deduction for the average expenses related to truck parking, showers, motels, laundry and Federal Express, in addition to a 50-percent deduction for the portion of the per diem allocated to meals. Using the testimony of the drivers, petitioners estimate the average daily nonmeal expenses at $7.61 per day per driver, for an additional deduction of $367,836 for 1995, $353,317 for 1996, and $354,527 for 1997. In support of this argument, petitioners rely on a sentence in Beech Trucking Co. v. Commissioner, 118 T.C. at 450, which petitioners interpret as an "outline of proof" for success in future cases: Having relied exclusively upon the deemed substantiation methods provided in the Revenue Procedures, petitioner has offered no independent substantiation of the amounts of lodging or incidental expenses that the Beech Trucking drivers might have incurred, or otherwise established any reasonable basis for allocating the per diem payments to meals, incidentals, and lodging expenses incurred by the drivers.30 30 In particular, the record does not establish the number of days per trip that the drivers would normally pay for separate lodging or for incidentals such as showers, laundry, local transportation, or overnight parking. As previously noted, it appears that at least some of the trips for which Beech Trucking paid per diem allowances involved no overnight travel. Petitioners misinterpret our description of the lack of evidence in Beech Trucking Co. as establishing a legal rule for future cases. The rules regarding deductibility of per diem allowances provide for one of two options: (1) Actual substantiation pursuant to section 274(d); or (2) deemed substantiation pursuant to the revenue procedures. Had petitioners not elected to be under the revenue procedures and had they instead substantiated the nonmeal expenses in compliance with section 274(d), petitioners would have been entitled to a full deduction for those expenses. However, since they elected to opt into the revenue procedures and not to substantiate these expenses as required by section 274(d), they are restricted to the rules under the revenue procedures. The per diem allowance in this case was deemed to be paid as a "meals only per diem allowance" under the test set forth in section 4.02(5) of the revenue procedures. When a per diem allowance is deemed paid as a "meals only per diem allowance", the revenue procedures provide for a 50-percent deduction of the entire per diem allowance and do not allow for a greater deduction when a taxpayer provides estimates regarding the average nonmeal expenses. Indeed, the purpose of the deemed substantiation under the revenue procedures is to avoid the need for additional evidence and subjective interpretations and to provide taxpayers with clear and objective tests, even if such tests fail to mirror actual expenditures. We also note that, for the reasons stated in Beech Trucking Co. v. Commissioner, supra at 450-451, petitioners' reliance on Johnson v. Commissioner, 115 T.C. 210 (2000), in support of their argument that they may use actual substantiation in addition to deemed substantiation, is misplaced. We reiterate that Johnson deals with section 4.03 of the revenue procedures, which is not at issue in this case. In reaching all of our holdings herein, we have considered all arguments made by the parties, and to the extent not mentioned above, we find them to be irrelevant or without merit. To reflect respondent's mathematical error in the statutory notice of deficiency with respect to the adjustments made to Continental for 1996, Decisions will be entered under Rule 155. DOVER CORPORATION AND SUBSIDIARIES, PETITIONER v. RESPONDENT Docket No. 12821-00. Filed May 5, 2004. D and H, United Kingdom corporations, were controlled for- 954(c)(1)(B)(iii), I.R.C. Rauenhorst v. Commissioner, 119 T.C. Robert D. Whoriskey, George Pompetzki, Eduardo A. OPINION HALPERN, Judge: Dover Corp. (petitioner) is the common parent of an affiliated group of corporations making a consolidated return of income (the group or affiliated group). By notice of deficiency dated September 14, 2000 (the notice), respondent determined deficiencies in Federal income tax for |