J.J. Zand - Page 27

                                        - 115 -                                       

          Borsharpour, who assisted Diesel Power in this venture, and                 
          petitioner deducted this amount on his 1976 Federal income tax              
          return.  This claimed commission expense was not an ordinary and            
          necessary business expense of petitioner.                                   
               In 1976 petitioner paid Don Kahler $1,500 and deducted it as           
          a commission expense on his 1976 Federal income tax return.  Mr.            
          Kahler was an interior decorator who assisted in redecorating               
          CTC's offices, kitchen, and conference room.  The payment of                
          $1,500 was in settlement of a disputed bill.  Although not a                
          commission expense, it was an ordinary and necessary business of            
          CTC, petitioner's sole proprietorship.                                      
               In 1978 petitioner paid $500 to Celia Longenbaker, an                  
          employee of Caspian Development Company (CDC), and $736.54 to TWA           
          for a Mr. Rayhanni's travel expenses to Chicago.  Petitioner                
          deducted these amounts as commission expenses in 1978.  There is            
          no evidence in the record of the business purpose of Mr.                    
          Rayhanni's travel to Chicago nor an explanation why the $500                
          check was written to Celia Longenbaker.  Therefore, this claimed            
          commission expense is not an ordinary and necessary business                
          expense of petitioner.                                                      
                      E.  Claimed Deductions for Consulting Fees                      
               Larry Castoe was a stockbroker who provided brokerage and              
          financial services to petitioner, Diesel Power, and others.                 
          Petitioner purchased stock through Mr. Castoe on one or two                 
          occasions as did Mr. Khalatbari.  Petitioner provided Mr. Castoe            




Page:  Previous  105  106  107  108  109  110  111  112  113  114  115  116  117  118  119  120  121  122  123  124  Next

Last modified: May 25, 2011