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between CTC and Diesel Power over Clark commissions when Mr.
Khalatbari began to be assertive about commissions. The sense of
the 1977 letter from Mrs. Conway and Mrs. Meier to petitioner
about the dispute concerning Clark commissions is that
petitioner's former control was being challenged. The evidence
shows that this question was resolved when Mr. Khalatbari paid
approximately $325,000 to CTC in June of that year. Thus, by the
end of 1977, and particularly after the transfer of petitioner's
last 40 percent of Diesel Power stock to the Khalatbaris,
petitioner had lost his control over Diesel Power. We conclude
that the $15,191.10 of commissions allocated to Diesel Power on
the 1978 CTC receipts journal were not taxable to petitioner.
K. Miscellaneous Companies/Goodyear
Petitioner's only argument with respect to the relatively
small commissions received from various companies was that a
commission-splitting agreement existed between CTC and Diesel
Power, and that the allocation of commissions on the CTC receipts
journal was in accordance with that agreement. As we have
discussed, petitioner's alleged agreement, even if it existed, is
irrelevant to the question before us of who actually earned the
commissions at issue. Although there is little record evidence
of the dealings with these particular companies, the record as a
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