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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's
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