- 215 - 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 inPage: Previous 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 Next
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