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brother, Monty Zand, in 1973. However, the amounts paid to Mr.
Sabety in 1973, 1974, and 1978 are not allowable.
The claimed "commission expense transfer payments" of
$23,686 in 1973 and $30,000 in 1974 to the Bank of Minora are
petitioner's ordinary and necessary business expenses and
therefore deductible.
Respondent has conceded a commission expense payment of
$10,000 to A.K. Said in 1973. Petitioner has conceded a payment
of $75,000 to Stewart & Stevenson in 1975.
The July 7, 1973, payment to an illegible payee in the
amount of $35,000 has not been proven to be an ordinary and
necessary expense of petitioner. Thus, it is disallowed.
Similarly, the $170 payment in 1973, and the $16,000 payment in
1975 were unidentified. Both deductions are disallowed.
For the year 1974 petitioner claimed a commission expense in
the amount of $75,000 paid to Hossein Zanganeh. Petitioner
reimbursed himself from Diesel Power's Bank of America account
for this amount. Mr. Zanganeh earned this commission for
assisting petitioner in selling Lockheed aircraft in Iran.
Respondent agrees that Mr. Zanganeh was paid for assisting
petitioner in the sale of the Lockheed aircraft and spare parts
to the Iranian Government. However, petitioner is not entitled
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