- 49 - 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 thatPage: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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