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recorded as commissions on the 1974 CTC receipts journal and are
not at issue. During 1974 Lockheed issued checks to Diesel Power
in the total amount of $995,543.23, all of which were deposited
into the Diesel Power Bank of America account. Lockheed issued
these checks payable to Diesel Power in accordance with
petitioner's instructions. Lockheed, WHIP, and Sunvaco are not
listed on Diesel Power's financial statements for the periods
ending March 20, 1974, and March 20, 1975. None of these checks
was reflected on the 1974 CTC cash receipts journal.
In the notice of deficiency for 1975 respondent increased
petitioner's income from Lockheed by $331,862.92. During the
taxable year 1975 Lockheed issued checks payable to CTC in the
total amount of $162,622.03. These checks were recorded in CTC's
1975 cash receipts journal; were deposited into CTC's CNB bank
account; were reported by petitioner as gross income for 1975;
and are not at issue. During the taxable year 1975 Lockheed
issued checks payable to Diesel Power in the total amount of
$331,862.92. These checks were issued in accordance with
petitioner's instructions. At least some of these checks were
payment in connection with the sale of P-3 aircraft. With the
exception of one check in the amount of $6,618.86, all of these
checks were deposited into the Diesel Power Bank of America
account. None of these checks was included by petitioner in his
1975 gross income.
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