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