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respondent cites an exhibit the accuracy of which we are unable
to identify. Therefore, we cannot determine that the total
amount of asserted deposits to the Zand FNCB London account of
$16,547.29 in respondent's appendix B is correct. We therefore
do not rely on appendix B for these asserted additional deposits
during 1973.
Respondent also asserts in appendix B that an additional
amount of $2,420.47 was deposited during 1976 to the Bank of
Teheran. However, respondent did not provide any support for
this amount. We also note that respondent has not filed a timely
amendment to answer with respect to this additional amount.
Respondent further asserts in appendix B that there was a 1977
payment in the amount of $3,221.00 to an unknown payee. However,
respondent provides no record support therefor.
Thus, there is no evidence that certain payments asserted in
the appendix B were made. Hence, we conclude that the stipulated
amounts constitute the correct figures. In addition, we hold for
petitioner with respect to respondent's assertions on brief that
there was additional 1976 income from Clark in the amount of
$681,783.24. Although this amount was stipulated to have been
paid to Diesel Power in 1976, respondent first made assertions
concerning these commissions on brief.
We now reach the issue of the Clark commission income for
the years 1973 through 1977. As an initial observation, we think
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