J.J. Zand - Page 33

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          journal for 1979 does not list any disbursements from CTC to CDC            
          as payment of management fees.                                              
               Thus, petitioner presented no evidence that the management             
          fees for 1978 and 1979 were paid; likewise, there is no evidence            
          of specific offsets made in payment of the management fees for              
          which the deductions were claimed.  Therefore, these claimed                
          management fees for 1978 and 1979 are not deductible by                     
          petitioner because they are not his ordinary and necessary                  
          business expenses; furthermore, the amounts claimed were not                
          shown to have been paid.                                                    
                G.  Claimed Deductions for Consulting Fees or Salary                  
               CDC issued two invoices to CTC, dated February 29, 1980, in            
          the amount of $6,487.83, and April 9, 1980, in the amount of                
          $461.73.  These invoices were offered in support of deductions              
          claimed for consulting fees and salaries of $102,101 and for                
          investment counsel fees of $4,500.  Petitioner's cash                       
          disbursements journal for 1980 does not reflect payment of these            
          amounts.  Therefore, petitioner is not entitled to deductions               
          claimed for consulting fees and salaries of $102,101 and                    
          investment counsel fees of $4,500 for 1980 because these amounts            
          are not his ordinary and necessary business expenses and the                
          amounts were not paid.                                                      









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