- 112 - 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 hisPage: Previous 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 Next
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