J.J. Zand - Page 219

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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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