J.J. Zand - Page 51

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                    Amount Claimed      Amount Allowed   Amount Disallowed            
          Year      by Petitioner       by Respondent   by Respondent                 
          1973      $98,481.64          $78,568.27          $19,913.37                
          1974      126,068.79          50,784.39           75,284.40                 
          1975      157,946.48          80,631.47           77,315.01                 
          1976      98,578.45           78,578.45           20,000.00                 
          1977      60,184.00           -0-                 60,184.00                 
          1978      74,970.00           -0-             74,970.00                     
          1979      41,444.00           -0-                 41,444.00                 
          1980      28,368.00                -0-            28,368.00                 
          1981      19,604.00                -0-            19,604.00                 

               Respondent disallowed the above travel and entertainment               
          expenses on the grounds that (1) they were not petitioner's                 
          ordinary and necessary business expenses, (2) they were not                 
          expended for the purposes designated, or (3) they were not                  
          substantiated in accordance with the requirements of section 274.           
               For each of the years 1973 through 1979 petitioner kept a              
          travel diary that reflected both his location and the names of              
          individuals he met with and entertained.  However, in most                  
          instances the business purpose and the place of lodging or                  
          entertainment are omitted.  Many of the individuals named in the            
          diaries, particularly those for 1973 through 1976, had business             
          relationships with Diesel Power, WHIP, All Patents, and IGOS.  No           
          witnesses named in petitioner's diaries provided testimony                  
          corroborating any specific meeting, entertainment, or expense               
          reflected in the diaries.  Furthermore, petitioner's employees              
          and office personnel acted pursuant to his directions; hence,               






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