- 212 - In the notice of deficiency for the taxable years 1978, 1979, and 1981 respondent increased petitioner's cost of goods sold in the amounts of $145,706, $95,633.60, and $5,862, respectively. These amounts are related to additional income from Galion that was included in the notice of deficiency for these taxable years. Having decided that petitioner's taxable income should be increased by the amounts from Galion, it follows that respondent correctly increased petitioner's cost of goods sold for those years. B. Commission Expenses For some of the commission expenses claimed as deductions for the years 1973 through 1978 petitioner failed to substantiate the business purpose and that the expenditures were his ordinary and necessary business expenses. Other than the unidentified amounts of $170 in 1973 and $16,000 in 1975, respondent concedes that the claimed amounts were paid. As to the amounts petitioner paid to Hillary Wood during the years 1973 through 1977, petitioner raises on brief the possibility that respondent would argue that the payments to Hillary Wood were illegal payments to Iranian Government officials or employees. Respondent has not taken that position. The reason for disallowing the payments to Hillary Wood in the notice of deficiency and in respondent's brief is that suchPage: Previous 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 Next
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