J.J. Zand - Page 37

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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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