J.J. Zand - Page 34

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               H.  Claimed Deductions for Legal and Professional Fees                 
               In 1975 petitioner paid DuBois Jansson $2,907.34 for                   
          services rendered with respect to acquiring railroad equipment              
          that would be sold to the Iranian State Railway.  Petitioner                
          deducted this amount on his 1975 Federal income tax return.  On             
          his tax returns and in his books and records for the years 1973             
          through 1977 petitioner took the position that the income from              
          only 40 percent of the products sold to Iranian State Railways              
          was taxable to him. Petitioner contends that the income from the            
          remaining 60 percent of the products sold constituted income of             
          Diesel Power.  Because we have found that all of the income was             
          petitioner's, he is entitled to deduct professional fees of                 
          $2,907.34 paid to DuBois Jansson for 1975.                                  
               During the years 1976, 1977, and 1978 petitioner deducted              
          legal fees paid to the law firm of George, Greek, King, McMahon &           
          McConnaughey in amounts that were at least $57,921.08,                      
          $57,419.26, and $25,059.21, respectively.  These fees were paid             
          for a variety of services, including acquisitions of real estate,           
          matters involving the Harris Corporation, handling the                      
          arbitration of a dispute between Clark and Diesel Power, handling           
          a home purchase matter for petitioner's brother, Monty Zand,                
          landlord-tenant issues, research concerning joint ventures,                 
          matters involving insurance and pension plans, tax matters,                 
          preparations of a will and trust, and a number of conferences               





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