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Amelia Corporation for the years 1975 and 1976, respectively, are
his ordinary and necessary business expenses.
Mr. Emilian was the service manager of Diesel Power. In
1975 petitioner paid lodging expenses, car rental, and medical
expenses for Mr. Emilian's son and $4,443 in unidentified cash
payments to Mr. Emilian. These payments totaled $7,028.33 and
were deducted on petitioner's 1975 return. Mr. Emilian was
accompanied by his family on a trip to the United States in 1975.
There are no receipts for the lodging, airfare, or car rental
expenses, nor is there any itemization of the $4,443 given to Mr.
Emilian in cash. Therefore, the claimed commission expense is
disallowed as an ordinary and necessary business expense of
petitioner.
In 1975 petitioner paid $1,000 to Mr. Bolanhemat, a former
employee of the Iranian State Railways, who was in the United
States for a training session. Petitioner deducted this amount
in 1975. Petitioner presented no evidence of how the $1,000 was
spent. Furthermore, petitioner presented no evidence of any
connection between Mr. Bolanhemat's training and petitioner's
business. Therefore, the claimed commission expense was not an
ordinary and necessary business expense of petitioner.
Diesel Power attempted to market Lockheed's earth resources
program in Iran. In 1976 petitioner paid $10,000 to Alfred
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