- 158 - petitioner's accountant, did not characterize the alleged $10,000 payment to Teheran National University as a charitable contribution, as stated in petitioner's brief, but characterized it as a business expense. There is no evidence to show the alleged payment of $10,000 to Teheran National University in 1974 was an ordinary and necessary business expense. Accordingly, petitioner is not entitled to deduct $10,000 as a charitable contribution or as a business expense for a payment to Teheran National University. With respect to the losses claimed in 1975 for the IDS/McCullough Oil Programs, there are no canceled checks, invoices, or any primary records in evidence from which it can be determined that any losses were incurred. There is no evidence of record establishing petitioner's basis. Consequently, he is not entitled to the claimed losses. It is not surprising that petitioner has changed his position in his brief with respect to the claimed automobile expenses because the evidence presented shows that records were not maintained to distinguish between personal and business use of the automobiles, and that a significant portion of the automobile use was for the business activities of CDC and other entities, rather than those of petitioner or CTC. Thus, hePage: Previous 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 Next
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