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CTC, Diesel Power, WHIP, or Sunvaco; he had heard of Mr.
Khalatbari, but he did not know Mr. Zanganeh.
By an agreement dated August 1, 1974, Diesel Power became a
distributor for Lockheed Missiles & Space Company, Inc. Although
the copy of this agreement in the record is unsigned, a
handwritten note attached to a copy sent to a CTC employee
indicates that Mr. Khalatbari had signed it on July 24, 1974.
None of the amounts at issue were earned by Diesel Power under
this agreement.
B. Payments by Lockheed
In the notice of deficiency for 1972 respondent adjusted
petitioner's income from Lockheed in the amount of $1,013,084.34,
which is equivalent to the two amounts Lockheed paid to WHIP and
Diesel Power in 1972, as follows. During the taxable year 1972
Lockheed issued checks payable to CTC in the total amount of
$418,111.59, which were recorded in CTC's cash receipts journal
and were deposited in the CTC CNB account. This amount is not in
dispute. During 1972 Lockheed also issued 12 checks to Diesel
Power which totaled $594,972.75. All but one of these checks
were deposited during 1972 into the Diesel Power Bank of America
account. It is unknown where the remaining check was deposited.
None of the amounts of these 12 checks was recorded in the 1972
CTC receipts journal. During 1972 Lockheed also issued 12 checks
to WHIP which totaled $418,111.41. Four of these checks,
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