J.J. Zand - Page 22

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                           B.  Cost of Goods Sold for 1977                            
               For the year 1977 petitioner's total cost of goods sold was            
          $525,714.36.  Galion was the principal payee, but others were               
          listed as GMOO, GMODC, Clark, and Cantwell.  Petitioner claimed             
          cost of goods sold on his Schedule C for 1977 in the total amount           
          of $594,530.  Therefore, cost of goods sold for 1977 was                    
          overstated by $68,815.64.                                                   
                   C.  Cost of Goods Sold for 1978, 1979, and 1981                    
               For the years 1978, 1979, and 1981 respondent increased                
          petitioner's deductions for cost of goods sold in the amounts of            
          $148,706, $95,633.60 and $5,862, respectively, because they were            
          related to additional income respondent determined that                     
          petitioner received from Galion.  Having found that petitioner's            
          taxable income should be increased by the amounts received from             
          Galion, respondent correctly increased petitioner's cost of goods           
          sold for those years.                                                       
                    D.  Claimed Deductions for Commission Expenses                    
               Hillary Wood resided in Paris, France, during the 1970's.              
          The only service provided by Ms. Wood to petitioner was to                  
          introduce him to Minister of Court Alam.  Petitioner met Ms. Wood           
          only once at a dinner party at which she accompanied an employee            
          of Continental Oil.  Petitioner made payments to Hillary Wood in            
          the amounts of $1,503.42, $18,041.04, $18,042.24, $18,043.44, and           







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