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income. In addition to these amounts, respondent asserts an
amount of $32,560.36 in 1978 which was listed as "Other" on the
CTC receipts journal. Petitioner presented no evidence that this
was not income; therefore, we conclude that it was.
In the notice of deficiency for 1978, 1979, and 1981
respondent determined that petitioner was entitled to additional
offsets for cost of goods sold in the amounts of $148,706.31,
$95,633.62, and $5,862, respectively. According to respondent's
statement on brief, these additional amounts were a result of
respondent's determination that additional Galion commissions
were includable in income in those years. Having found that
petitioner's taxable income for those years should be increased
by the amounts received by Galion, it follows that respondent
correctly increased petitioner's cost of goods sold for those
years.
J. Clark
We note initially some matters pertaining to evidence and
pleading for certain years. In addition to the amounts that were
stipulated by the parties, respondent asserts in the proposed
findings of fact that there were deposits by Clark during 1973 to
the Zand FNCB London account of amounts in excess of $16,545, and
that there was unreported income in a similar (but not identical)
amount. However, either the record materials cited by respondent
in support thereof in appendix B relate to deposits in 1974 or
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