- 113 -
1974 income tax return. There is no evidence in the record of
any business purpose for this payment.
Ladham Alam was the daughter of Mr. Daftari. Petitioner
provided her with funds for her schooling. Petitioner paid
Ladham Alam $4,756 and recorded the payments as expenses of
Diesel Power. Petitioner claimed a deduction of $5,250 on his
1974 return. There is no evidence in the record of an ordinary
and necessary business purpose for the payments to Ladham Alam in
1974. Thus, it is disallowed as an ordinary and necessary
business expense of petitioner.
Jack Rose of General Motors asked petitioner to be involved
in the efforts to sell GM locomotives to Pakistan. During the
period March 10 through March 14, 1974, petitioner met with
associates of Mr. Khilnani with respect to the sale of GM
locomotives in Pakistan. An agreement was reached on March 14,
1974. Mr. Khilnani was employed by or affiliated with Amelia
Corporation. Petitioner paid Amelia Corporation $234,033.42 in
1975 and $362,003.36 in 1976, and claimed deductions for these
amounts on his Federal income tax returns. There is no evidence
that Diesel Power was involved in the sale of GM locomotives to
Pakistan; all items sold by Diesel Power were shipped exclusively
to Iran. Consequently, the commission expenses in the amounts of
$234,033.42 and $362,003.36 claimed by petitioner with respect to
Page: Previous 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 NextLast modified: May 25, 2011