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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 and
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