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Iran. This program was not successful. Since earth resources
was a Diesel Power program, the amounts paid by petitioner to Mr.
Borsharpour were not his ordinary and necessary business
expenses.
The 1976 payment of $1,500 to Don Kahler in settlement of a
disputed bill was an ordinary and necessary business expense of
CTC, petitionner's sole proprietorship. Therefore, this
deduction is allowed.
There was no business purpose shown for either the 1978 $500
payment to Celia Longenbaker or the 1978 payment in the amount of
$736.54 to TWA for Mr. Rayhanni's Chicago travel expenses.
Hence, both deductions are disallowed.
C. Consulting Fees
For the years 1977, 1978, and 1979 petitioner made payments
of $18,266.10, $14,377.13, and $12,445.39, respectively, to Larry
Castoe. Included in the payments made on behalf of Mr. Castoe
are payments to CDC, stock exchanges fees, expenses for financial
publications and services, and expenses for items for which the
business purpose is not readily apparent.
Mr. Castoe was a stockbroker in Columbus, Ohio, who made his
services available to CTC, Diesel Power, petitioner and other
Iranians to make investments in stock on their behalf. Mr.
Khalatbari also purchased stock through Mr. Castoe. Petitioner
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