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was involved in earning this income, both personally and through
the actions of his CTC employees. At petitioner's instructions,
some of the Morgan payments were issued directly to Diesel Power
and some directly to CTC. Petitioner recorded the CTC payments
as CTC commissions on the receipts journal, and petitioner did
not report as income any of the checks issued to Diesel Power in
1976. This arrangement effectively resulted in the split of
commissions for 1976. The 1977 payments were split on the CTC
receipts journal. We conclude that the split of the commissions
such as was made here reflected the understanding of petitioner
and Diesel Power as to the work involved in earning the Morgan
commissions. By the time these payments were made, petitioner
had relinquished ownership of some of his Diesel Power stock.
The actual division of commissions for 1976 and 1977 appears to
have adequately reflected the evidence of division of effort on
the part of Diesel Power and petitioner or CTC to implement the
Morgan arrangement. Accordingly, we hold for petitioner on the
Morgan amounts.
G. Harnischfeger
There is no discussion in the parties' briefs concerning
respondent's determination in the 1974 notice of deficiency for
Harnischfeger. The amount of $525.41 is determined as income
from Harnischfeger. However, there is no evidence in the record
of income from that company, although it precisely matches an
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