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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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