J.J. Zand - Page 24

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               The Bank of Minora was a small Iranian bank that would                 
          exchange U.S. dollars for Iranian rials.  Petitioner and CTC                
          employees used the Bank of Minora to make transfers to Diesel               
          Power.  In 1973 and 1974 petitioner deducted as "commission                 
          expense transfers" to the Bank of Minora the amounts of $23,686             
          and $30,000.  The conversion of currency from U.S. to Iranian was           
          an ordinary and necessary business expense of petitioner.                   
               Petitioner's cash disbursements journal for 1973 lists a               
          payment of $35,000 on July 7, 1973, to an illegible payee.  This            
          amount was deducted as a commission expense.  It has not been               
          proven to be an ordinary and necessary business expense of                  
          petitioner.                                                                 
               There is no evidence in the record to support unidentified             
          commission expenses in the amounts of $170 and $16,000 for the              
          years 1973 and 1975, respectively, that were claimed by                     
          petitioner on his 1973 and 1975 income tax returns.                         
               Petitioner paid Hossein Zanganeh $80,000 in 1973 and $75,000           
          in 1974 for assisting him in selling Lockheed aircraft in Iran.             
          The $80,000 payment is not at issue.  Petitioner deducted the               
          1974 payment as a commission expense.  However, Diesel Power                
          reimbursed petitioner for this payment.                                     
               Sadek Massey was an employee of Diesel Power.  Petitioner              
          paid Sadek Massey $2,000 in 1974 and deducted that amount on his            







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