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during 1976 with Mr. Khilnani and Mr. Khalatbari at the London
office concerning the Pakistani sale. Petitioner apparently
hired Mr. Khilnani to do some other work for him in Pakistan on
matters unrelated to this case.
F. Payments Made by General Motors
In the notice of deficiency for 1973 respondent increased
petitioner's income from GM in the amount of $8,176.37. In the
amendment to answer respondent asserted an increase in
petitioner's 1973 income from GM to $17,943.61. During 1973 GM
deposited �7,824.99 (British pounds) into the Zand FNCB London
account, the equivalent of $18,146.15. This amount was not
recorded in the 1973 CTC receipts journal.
There are two GM commission amounts at issue for 1974. The
first is a determination in the notice of deficiency for 1974
that there was $414,855.46 in unreported "per books" income from
GM. This amount is a portion of certain checks paid by GM to CTC
for the sale of locomotives to Iran in the total amount of
$608,194.47. All of these checks were deposited in full into the
CTC CNB account. The CTC cash receipts journal showed
$166,353.43 of this total amount as commissions earned by CTC.
Petitioner included this amount in his 1974 income. The balance
of $441,841.04 is shown as commissions earned by Diesel Power and
was not reported by petitioner on his 1974 return. The second
amount from GM at issue for 1974 involves payments from GM that
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