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Florida. Petitioner also purchased a home in Columbus, Ohio, for
his daughter and Mr. Dinunzio and bought him a Cadillac.
Accordingly, we hold that the $9,000 paid by petitioner to
Mr. Dinunzio did not constitute an ordinary and necessary
business expense, and, therefore, the deduction is disallowed.
Additionally, petitioner's 1980 rent expense deduction in the
amount of $6,451.86 is disallowed. The expense was personal;
i.e., rent paid for a New York City condominium for petitioner's
daughter.
H. Interest Expense
For the years 1973 through 1980 respondent disallowed
deductions claimed by petitioner for interest expenses of $3,250,
$3,000, $142,500.17, $27,579.67, $3,093.12, $20,034, and $74,879,
respectively.
With respect to the amounts claimed as interest expense to
Mr. Sabety, petitioner substantiated payments in the amounts of
$3,000 for 1973, $3,000 for 1974, $2,950.96 for 1975, $3,000 for
1976 and $1,000 for 1977. However, petitioner presented no
evidence to show a debtor-creditor relationship between himself
and Mr. Sabety. In 1967, Mr. Sabety invested $20,000 through
petitioner in an entity known as Caspian International Jordan.
Petitioner did not incur personal liability to Mr. Sabety for the
amount invested, nor did he sign a note. From this investment
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