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concerning various farms. Of the total amounts paid to the
George, Greek law firm for the years 1976, 1977, and 1978, the
amounts of $20,607,58 (1976), $17,950.59 (1977), and $6,315.68
(1978) were paid with respect to the Clark arbitration involving
Diesel Power.
Other legal and professional fees paid by petitioner with
respect to the Clark arbitration matter involving Diesel Power
were payments to the law firm of Walder, Wyss, & Maier in the
amounts of $1,400.85 for 1976 and $761.71 for 1977, Coudert
Freres in the amount of $500 in 1976, and a deposit paid to A.
Sarasin & Cie in the amount of $22,500 in 1977.
When Clark canceled its distributorship with Diesel Power,
Diesel Power was left with Clark equipment inventory on hand that
it could not sell. The distributorship agreement provided for
arbitration to resolve such disputes. In this matter Diesel
Power was represented by the George, Greek, law firm.
The legal and professional fees claimed by petitioner as
paid to George, Greek in the amounts of $57,921.08, $57,419.26,
and $25,059.21 for the years 1976, 1977, and 1978, respectively,
are not deductible because it has not been shown that these
amounts were ordinary and necessary business expenses of
petitioner. The legal and professional fees deducted by
petitioner concerning the Clark arbitration matter and paid to
Walder, Wyss & Maier in the amount of $1,485 for 1976 and $761.71
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