J.J. Zand - Page 134

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               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 such                 







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