- 124 - Iranian lawyer. Petitioner deducted these two payments in 1978. There is no evidence as to the business purpose of these payments or why they were made to Sandra Rossi and Celia Longenbaker instead of Mr. Shamloo. Therefore, they are disallowed. In 1979 petitioner deducted legal fees paid to the New York law firm of White & Case in the amount of $3,710. Of this amount $2,660 represents fees paid in connection with the purchase of a cooperative apartment in New York City for petitioner's daughter. This amount ($2,660) is disallowed as an ordinary and necessary business expense of petitioner. In 1979 petitioner deducted a legal fee paid to the law firm Chester, Saxbe, Hoffman & Wilcox in the amount of $910. There is no evidence in the record of the business purpose for this payment. Therefore, it is disallowed. I. Claimed Deductions for Salaries and Wages In 1974 and 1976 petitioner paid his brother, I.J. Zand, $9,000 and $5,000, respectively. Petitioner deducted these amounts as salaries or wages. I.J. Zand was not paid the amounts due to any employment by CTC or petitioner. Rather, I.J. Zand was an employee of Diesel Power from 1971 through 1976. Therefore, the deducted amounts are disallowed. J. Claimed Deductions for Office Expenses In 1973 petitioner acquired a desk costing $1,202.24 and other furniture costing $296.25. He expensed these purchases andPage: Previous 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 Next
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