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However, these payments were recorded in CTC's journal as made to
Mr. Shamloo, an Iranian lawyer. No business purpose for the
payments was shown. No explanation was given for why the
payments were made to Sandra Rossi and Celia Longenbaker instead
of Mr. Shamloo. Hence, the $5,000 deduction is disallowed.
For the year 1979 respondent disallowed legal and
professional fees in the amount of $10,082 claimed by petitioner.
Of this amount, $3,710 was paid to the New York law firm of White
& Case. Respondent concedes that $850 of the amount paid is
deductible by petitioner. However, the remaining amounts paid to
White & Case represent fees paid in connection with the purchase
of a cooperative apartment in New York City for petitioner's
daughter. That amount is petitioner's personal expense and is,
therefore, not deductible as a business expense.
Petitioner deducted $910 on his 1979 income tax return for
legal fees paid to Chester, Saxbe, Hoffman & Wilcox. Because the
business purpose of this payment was not shown, the $910
deduction is disallowed.
F. Salaries and Wages
There remain in dispute for 1974 and 1976 payments to
petitioner's brother, I.J. Zand, in the amounts of $9,000 and
$5,000, respectively, claimed as salaries and wages. Unlike the
commission expenses, the payments to I.J. Zand claimed as
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