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to any deduction for 1974 because he was reimbursed from Diesel
Power's Bank of America account for that payment.
No business purpose was shown for either the $2,000 payment
to Sadek Massey in 1974, or the $4,756 payment to Ladham Alam in
1974. (We note that petitioner claimed a deduction of $5,250 for
the $4,756 payment to Ms. Alam.) Thus, both deductions are
disallowed.
Having found that all the commissions paid by General Motors
with respect to the sale of locomotives to Pakistan constitute
income to petitioner, we conclude, and respondent agrees, that
commission expenses paid to Amelia Corporation of $234,033.42 in
1975 and $362,003.36 in 1976 are deductible by petitioner.
Petitioner failed to show a business purpose to substantiate
the lodging expenses, car rental, and medical expenses for Mr.
Emelian's son. Petitioner failed to itemize the $4,443 cash
payment to Mr. Emelian. Hence, the total deduction of $7,028.33
is disallowed.
Petitioner failed to prove that the $1,000 payment to Mr.
Bolanhemat in 1975 was his ordinary and necessary business
expense. Thus, this deduction is disallowed.
For the year 1976, petitioner deducted a commission expense
of $10,000 paid to Alfred Borsharpour, who assisted Diesel Power
in attempting to market Lockheed's earth resources program in
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