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respondent increased petitioner's income from Goodyear by
$2,695.28.
In the notice of deficiency for 1977 respondent determined
that petitioner had unreported income from Diesel Power sales
commissions. Of these payments $10,952.15 is attributed to
Exxon, $3,000 to Orton, and 56 cents to Atlantic Richfield. The
following payments were recorded in the CTC receipts journal for
1977:
CTC Diesel Power
Payor Amount Commission Commission
Exxon $147,558.45 $7,301.43 $10,952.15
Orton 5,000.00 2,000.00 3,000.00
Atlantic
Richfield 2.88 .38 .56
All payments listed above were deposited to the CTC CNB account
during 1977.
III. Interest and Dividend Income--First National City Bank,
London, England, and Crown Life Insurance Company
During 1974 and 1975 petitioner maintained an account with
First National City Bank (FNCB) in London, England, account
number 1612131. This account generated interest income of
$38,055.71 in 1974 and $43,641.69 in 1975. Petitioner also
received payments from Crown Life Insurance Company of $436.50 in
1974 and $445.30 in 1975, which were recorded as "dividends" in
CTC's cash receipts journal.
Petitioner did not include the interest from the FNCB
account or the dividends from Crown Life on his 1974 or 1975
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