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service provided, or the business purpose of the one-time charge
of $6,262.30. Thus, since petitioner has not established the
business purpose for this expense or that it is an ordinary
rather than a capital expense, no deduction is allowed.
For the year 1978, petitioner deducted $9,000 for
condominium rent paid to his son-in-law, Joseph Dinunzio. The
rent was prepaid in 1978 for the year 1979, and was based on the
estimated fair rental value of the condominium plus the cost of
furnishing it. Mr. Dinunzio acquired the condominium in the fall
of 1978 from the Riviera Condominium Company of Naples, financing
the purchase with a 100-percent mortgage from Dollar Savings of
Ohio. Petitioner was a shareholder in the Riviera Condominium
Company of Naples.
The amount paid to Mr. Dinunzio for the use of this
condominium does not constitute an ordinary and necessary
business expense of petitioner. Rather, the evidence shows that
petitioner was merely continuing to help his daughter and her new
husband get established. Petitioner had already provided his
son-in-law with employment immediately after Mr. Dinunzio
graduated from college. Furthermore, shortly thereafter, Mr.
Dinunzio's duties were expanded to include the vice presidency at
no less than four business entities controlled by petitioner;
i.e., CDC, Caspian Machinery, Caspian Electric, and Caspian
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