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$18,043.44, respectively, for the years 1973 through 1977. He
deducted these amounts. These claimed commission expenses and
other business expenses with respect to Hillary Wood were not
ordinary and necessary business expenses of petitioner.
In 1973 and 1974 petitioner's brother, I.J. Zand, an
employee of Diesel Power, performed services for petitioner. The
payments he made to I.J. Zand of $16,100 in 1973, $25,000 in
1974, and $2,130 in 1978 were made because Diesel Power could not
fully compensate I.J. Zand. Petitioner deducted these amounts as
a commission expense. The claimed commission expenses constitute
ordinary and necessary business expenses of petitioner.
Petitioner's brother, Monty Zand, assisted petitioner and
Diesel Power in selling some equipment in Iran. Petitioner paid
him $15,000 in 1973 and deducted this amount on his 1973 income
tax return. The commission expense paid to Monty Zand was an
ordinary and necessary business expense of petitioner.
Mehdi Sabety was an employee of Diesel Power. He was not
employed by CTC. He did not render any services to CTC or to
petitioner. Therefore, the commission expenses in the amounts of
$11,000, $10,000, and $2,000 claimed by petitioner with respect
to Mehdi Sabety for the years 1973, 1974, and 1978, respectively,
were not his ordinary and necessary business expenses.
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