- 6 - The record contains a credit memo on petitioner's letterhead to AA&H dated October 25, 1989, bearing an order date of October 24, 1989, and referring to a "commission credit for Turkey 25 contract" in the amount of $1,176,691.86. The record contains a series of documents beginning with an advice dated July 14, 1988, from Chase Manhattan Bank in the United States to Chase Manhattan Bank, Istanbul, Turkey, to pay the bid bond under the second agreement for the sale of 25 trenching machines, shipping and insurance documents indicating that at least 23 of the 25 trenching machines under the second sales agreement had been shipped during the fiscal year ended September 30, 1989, culminating in petitioner's invoice to the Turkish Government that, as of February 27, 1990, the balance due petitioner on the sale of 25 trenching machines amounted to $1,327,980.84, and that, as of March 9, 1990, petitioner had not yet been paid this amount. On petitioner's Form 1120, U.S. Corporation Income Tax Return, for its fiscal year ending September 30, 1989, petitioner accrued a deduction of $1,176,692 for commissions. Respondent disallowed $168,099 of the claimed deduction on the ground that petitioner had not established that this amount had been paid or incurred for the purpose designated or that it qualified as aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011