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deposit was made to petitioner's FNCB account, we hold for
petitioner with respect to this alleged 1975 payment.
With regard to the stipulated 1976 payment from Ingersoll-
Rand of �5,494.40 to the Zand FNCB London account, respondent
asserts that the average monthly exchange rate for British pounds
to dollars in March 1976 was �1.960 to $1. Respondent offers no
support for this exchange rate. Accordingly, respondent's
allegation that �5,494.40 was equivalent to $10,769.02 is
unsubstantiated. Our research indicates that the correct
exchange rate was �1.9454 to $1; accordingly, the �5,494.40
stipulated to have been deposited into the Zand FNCB account were
equivalent to $10,688.05. Petitioner contends that this
stipulated payment did not constitute income to him because it
belonged to Diesel Power. To the contrary, respondent contends
that these funds were transferred at the direction of
petitioner's employee and thus, were income to him. We conclude
that, although petitioner's employee may have directed the
payment of these commissions, the record indicates that most of
the effort involved in earning them was performed by Diesel
Power. Accordingly, we hold for petitioner with respect to the
$10,688.05.
Respondent also claims that there was an unreported $120,000
payment from IGOS to petitioner in 1976 for commissions from
Ingersoll-Rand. In support thereof, respondent cites only to a
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