J.J. Zand - Page 112

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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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