- 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, he
Page: Previous 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 NextLast modified: May 25, 2011