J.J. Zand - Page 237

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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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