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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
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