J.J. Zand - Page 49

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                               O.  Claimed Rental Loss                                
               In 1975 petitioner claimed a rental loss of $41,049.53.  In            
          the notice of deficiency respondent reduced the loss by $35,228.            
          There is no evidence to support rental expenses claimed by                  
          petitioner in computing his rental loss for the year 1975.                  
          Therefore, it is not allowed.                                               
                           P.  Claimed Rent Expense--London                           
               In 1976 petitioner deducted $10,000 paid to his brother-in-            
          law and sister, Farshid and Diana Khalatbari, for the use of                
          their London apartment, limousine, and chauffeur.  He did not               
          present any evidence to show the number of days he used the                 
          London apartment or the business purpose for such use.                      
          Therefore, because petitioner has not shown that this $10,000               
          rental expense was an ordinary and necessary business expense or            
          that he satisfied the record-keeping requirements of section 274            
          with respect to foreign travel, he is not entitled to a deduction           
          for rental expense.                                                         
                    Q.  Claimed Deduction for Loan Origination Fee                    
               On May 25, 1978, petitioner paid W. Lyman Case & Company               
          $7,000 as a loan origination fee for the purchase of the Madison            
          County Farm.  He deducted this payment in 1978.  The Madison                
          County Farm was owned by CDC in 1978.  Therefore, petitioner is             
          not entitled to the claimed deduction for the loan fee because              







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