J.J. Zand - Page 59

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               Petitioner has not proven that he is entitled to the claimed           
          deductions for travel and entertainment expenses and for                    
          automobile expenses for 1981.                                               
          IX.  Claimed Dependency Exemption and Charitable Contribution               
               Deductions                                                             
           A.  Dependency Exemption Deduction Claimed for Tara Daneshvari             
               For each of the years 1973 and 1974 petitioner claimed a               
          dependency exemption for Tara Daneshvari.  She was the daughter             
          of Dr. and Mrs. Daneshvari, Iranians who were living in Columbus,           
          Ohio.                                                                       
               There is no evidence in the record documenting the period of           
          time that Tara resided with petitioner, the amount of support               
          provided by him to her, the amount of support provided by Tara's            
          parents to her, or facts concerning her status as a resident or             
          nonresident alien.  Therefore, petitioner is not entitled to                
          dependency exemption deductions claimed for Tara for the years              
          1973 and 1974.                                                              
            B. Deduction for Charitable Contribution Claimed for Property             
          Transferred to the City of Columbus, Ohio                                   
               On Schedule A of his 1976 Federal income tax return                    
          petitioner claimed $51,662.62 as a charitable contribution                  
          arising from the transfer of a house located on 3404 Riverside              
          Drive, Columbus, Ohio, to the City of Columbus.  Included in the            
          amount claimed was $13,000 paid by CTC check dated December 22,             
          1976.  This $13,000 check was issued at petitioner's direction to           





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