J.J. Zand - Page 218

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          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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