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Amelia Corporation. The record contains a 1976 memo to the file
in which it is stated that there was a $50,000 payment to Amelia
Corporation, which petitioner stated was for "expenses".
However, the record does not reveal when this payment was made,
if at all, or for what. Therefore, the payment has not been
proven to be a deductible expense.
D. SEDCO, IMICO, IMISS
Although the joint venture and dealership agreements at
issue were between Diesel Power and Stewart & Stevenson, SEDCO,
and IMICO, the record shows that there was virtually no
involvement in these arrangements by Diesel Power; rather, they
were agreements with Diesel Power in name only. Petitioner and
his CTC employees made all the arrangements to create and
implement these ventures; Diesel Power was simply informed about
them after the fact. While petitioner's testimony attempts to
convince us that CTC merely assisted with some of the paperwork
involved, the contemporaneous documents indicate otherwise; i.e.,
they show that petitioner was actively involved in this venture
and that Diesel Power was not. Therefore, petitioner's income
includes all commissions received from SEDCO, SEDIRAN, IMICO, and
Stewart & Stevenson during 1973, 1974, 1975, and 1976 which are
recorded on the CTC receipts journal as Diesel Power commissions.
With regard to the allegation in the 1973 notice of
deficiency of $1,000 in unreported income from Stewart &
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