J.J. Zand - Page 156

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          respect to amounts of such loans, dates of such loans, interest             
          rates, or payment schedules.  Since petitioner has failed to                
          establish that $96,254.78 or any portion of the $125,000 paid to            
          Diesel Power on December 30, 1975, is interest expense, the                 
          deduction is not allowed.                                                   
               For the years 1975 and 1977, petitioner deducted interest              
          expenses in the amounts of $2,049.04 and $688.32, respectively.             
          Neither payment can be identified.  Therefore, petitioner has               
          failed to meet his burden of proof with respect to these amounts,           
          and the deductions are disallowed.                                          
               For the year 1976 petitioner deducted $24,400.87 paid to               
          W.P. Glass on June 1, 1976, as interest expense.  This amount was           
          recorded in CTC's cash disbursements journal as an interest                 
          payment for a ranch.  However, the entry in this journal is not             
          accurate.  In fact, the payment of $24,400.87 to Mr. Glass was              
          for the acquisition of real estate, a ranch purchased as an asset           
          of the A-Z Ranch Partnership.  Petitioner admits that the payment           
          to Mr. Glass was a portion of the purchase price of real property           
          that was an asset of the partnership.  Thus, this amount does not           
          constitute interest expense.  Sec. 163.                                     
               For the years 1979, 1980, and 1981 petitioner claimed                  
          interest expenses paid to the Mirhosseini family in the amounts             
          of $15,000, $44,879, and $36,000, respectively.  On or about                
          September 10, 1979, three members of the Mirhosseini family each            





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