- 213 - payments were not ordinary and necessary business expenses. Petitioner, however, attempts to show that the payments to Ms. Wood were ordinary and necessary business expenses. Over a period of 4 years and 1 month petitioner paid Hillary Wood about $73,500. Ms. Wood resided in Paris, while petitioner resided in Columbus, Ohio, and carried on most of his business activities in Iran. Petitioner was able to point to only one Iranian Government official to whom he received an introduction through Ms. Wood. Further, he was already well connected with several high ranking officials in the Iranian Government. Therefore, it is unlikely that petitioner needed someone from France to assist him in meeting Iranian Government officials. We think it is clear that very few, if any, of the services Hillary Wood provided to petitioner qualify as ordinary and necessary business expenses for payments of $1,500 per month for 49 consecutive months. Therefore, we sustain respondent's determination. Petitioner claimed that the amounts of $16,100 in 1973, $25,000 in 1974, and $2,130 in 1978, paid to his brother, I.J. Zand, are deductible. As reflected in our findings of fact, we hold that the amounts paid as commissions are petitioner's ordinary and necessary business expenses. The same thing is true with respect to $15,000 in commissions paid to petitioner'sPage: Previous 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 Next
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