- 179 - 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 &Page: Previous 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 Next
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