- 30 -
totaling $171,806.42, were deposited into the WHIP Barclays
Bahamas account during 1972. The record does not indicate where
the remaining checks were deposited. None of the amounts paid by
Lockheed to WHIP during 1972 was recorded in the 1972 CTC
receipts journals. Lockheed issued the checks in the names of
CTC, Diesel Power, and WHIP in accordance with instructions from
petitioner or a CTC employee. Petitioner reported no dividend or
other gross income from WHIP on his income tax return for 1972.
In the notice of deficiency for 1973 respondent increased
petitioner's income from Lockheed by $657,735.96, which is the
sum of amounts paid to WHIP and Diesel Power in 1973 as follows.
During 1973 Lockheed paid Diesel Power a total of $466,147.55,
which was deposited into the Diesel Power Bank of America
account. None of this amount was recorded in the 1973 CTC
receipts journal. During 1973 Lockheed made payments to WHIP in
the total amount of $191,588.41, which were deposited into the
WHIP Barclays Bahamas account. These payments were not recorded
in CTC's cash receipts journal for 1973. Petitioner reported no
income from WHIP on his income tax return for 1973.
In the notice of deficiency for 1974 respondent increased
petitioner's income from Lockheed by $995,543.23. During 1974
Lockheed paid CTC $226,920.17 in connection with the C-130 sales
and $270,851.40 in connection with the P-3 aircraft sales, which
were deposited into CTC's CNB account. These amounts were
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