J.J. Zand - Page 57

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          deductions that petitioner claimed for travel and entertainment,            
          cash expenses, and car expenses in that year.  Only $67,686.10              
          was recorded on CTC's disbursements journal.  Petitioner's travel           
          diary reflects cash expenses of no more than $6,888.  Many of the           
          cash expenses were personal.                                                
               Petitioner's travel and entertainment expenses claimed in              
          1978 included expenses with respect to his various activities in            
          Naples, Florida, including activities of the separate                       
          corporations and partnerships of Caspian Development, dealings              
          with Bill McCabe, and the Gramercy.  His claimed travel and                 
          entertainment expenses in 1978 also included expenses relating to           
          the sale of his Diesel Power stock and his arbitration with Mr.             
          Khalatbari.                                                                 
               Petitioner has not established which travel and                        
          entertainment expenses for 1978 were personal and which were                
          business related.  Therefore, he is not entitled to the claimed             
          deduction for that year.                                                    
                                         1979                                         
               Although petitioner claimed a deduction for 1979 of $41,444            
          for travel and entertainment expenses and for automobile expenses           
          of $3,936, only $33,406.04 is recorded in CTC's disbursements               
          journal.  Petitioner conceded $2,141.25 as unidentified.                    
               Travel and entertainment expenses that petitioner claimed in           
          1979 included expenses relating to various projects in Naples,              





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