J.J. Zand - Page 44

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               For the year 1975 petitioner claimed an interest expense               
          paid to Diesel Power in the amount of $137,500.17 on his original           
          income tax return.  Petitioner's amended tax return for 1975                
          reduced the interest expense paid to Diesel Power by $41,245.39.            
          On December 30, 1975, petitioner paid Diesel Power $125,000.                
          This amount is listed in CTC's cash disbursements journal under             
          the transfer column; it is noted as "interest on loan" drawn by             
          petitioner.  In 1978 his accountant listed this payment as a                
          transfer.                                                                   
               Petitioner did not introduce into evidence any notes or                
          other loan documents evidencing a debtor-creditor relationship              
          between himself and Diesel Power.  Testimony presented at trial             
          with respect to moneys borrowed by petitioner from Diesel Power             
          was not specific with respect to the amounts of such alleged                
          loans, dates of such loans, interest rates, or repayment                    
          schedules.  Therefore, petitioner is not entitled to any interest           
          deduction in 1975 for the amount paid to Diesel Power in 1975.              
               On June 1, 1976, petitioner paid W.P. Glass $24,400.87.                
          This amount was deducted as interest expense.  This payment was             
          for the purchase of real estate for the A-Z Ranch Partnership.              
          Therefore, it is not deductible as interest expense.                        
               In 1976 petitioner made three payments to Crown Life                   
          Insurance totaling $178.80.  In 1976 he deducted $219.80 as                 







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