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Lar Exploration project. None of the amounts of these checks was
recorded on CTC's cash receipts journal or included in
petitioner's 1974 gross income.
In the notice of deficiency for 1975 respondent increased
petitioner's income from Ashland by $452,328.45, which is the sum
of $69,078.45 and $383,250. Ashland issued a check payable to
the Banque de Paris for All Patents on February 20, 1975, in the
amount of $69,078.45 and a check payable to All Patents in the
amount of $383,250 on April 21, 1975. Both checks were deposited
in the Diesel Power Banque de Paris account. Ashland is not
reflected as a client or a source of income on Diesel Power's
financial statements for the periods ending March 20, 1974, or
March 20, 1975. Neither of these payments was included in
petitioner's 1975 gross income.
In the notice of deficiency for 1976 respondent increased
petitioner's income from Ashland by $198,750. By an assignment
agreement dated December 15, 1975, All Patents and the Banque de
Paris assigned to petitioner their rights under the
April 4, 1974, agreement with Ashland. The assignment agreement
was signed by someone named "Betterman" on behalf of All Patents.
By a letter agreement in December 1975, agreements between
Ashland and All Patents were terminated. In December 1975,
Ashland issued a check in the amount of $265,000 payable to
petitioner. The payment was described in the particulars section
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