- 164 - directly to Diesel Power that were not reported as income by petitioner and which respondent did not allocate to petitioner as income in the deficiency notices. In other words, respondent appears to concede that Diesel Power did actually earn a considerable amount of commissions in its own right. The areas of contention mostly involve commissions that were paid to CTC, a portion of which were then attributed to Diesel Power on the CTC receipts journal, as well as certain commissions that were issued in the name of Diesel Power that were allegedly earned by CTC or petitioner, but were not reflected on the CTC receipts journal. Third, petitioner contends that he relinquished his controlling interest in Diesel Power in 1971 or 1974. He testified that in 1971 he and Mr. Khalatbari had a dispute because Mr. Khalatbari wanted to be a Diesel Power shareholder and that, as a result of this dispute, Mr. Khalatbari left Diesel Power for a few days. Petitioner then indicated that, when Mr. Khalatbari returned, petitioner agreed to transfer 60 percent of his interest in Diesel Power to Mr. and Mrs. Khalatbari. This agreement was allegedly not "formalized" until 1974. The record shows that petitioner received 11,750,000 rials for the transfer of his 60-percent interest. When petitioner transferred the remainder of his stock to the Khalatbaris in 1977, there is no disagreement that there was a payment of money. We conclude that there was in fact a reduction of petitioner's ownership in DieselPage: Previous 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 Next
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