- 135 - 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 becausePage: Previous 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 Next
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