J.J. Zand - Page 137

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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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