J.J. Zand - Page 238

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          were deposited into the Zand FNCB London account.  In the notice            
          of deficiency for 1974 respondent determined that there was                 
          $13,221.35 in "other unreported" income from GM.  In the                    
          amendment to answer respondent asserted that petitioner failed to           
          report 1974 income from GM in the amount of $25,260.24.  During             
          1974 GM deposited a total of �10,760.20 into the Zand FNCB London           
          account after CTC corrected the amount and gave instructions as             
          to the deposit location.  This was equivalent to $25,260.24.                
          None of this amount was recorded in the CTC cash receipts journal           
          for the taxable year 1974 or as 1974 income by petitioner.                  
               In the notice of deficiency for 1975 respondent determined             
          that there was $1,589.04 in "other unreported" income.  In the              
          amendment to answer respondent asserted that the notice of                  
          deficiency incorrectly included $507.21 as unreported income and            
          that the correct amount should have been $1,204.12.  On                     
          April 25, 1975, GM deposited �507.21 into the Zand FNCB London              
          account.  Petitioner concedes that this amount was equivalent to            
          $1,204.12.  None of this amount was included in the CTC receipts            
          journal for 1975.  In the notice of deficiency for 1975                     
          respondent also determined that petitioner had "Per Books                   
          Unreported" income from GM of $1,050,285.15.  During 1975 GM paid           
          CTC commissions in the total amount of $1,995,906.02, all of                
          which were deposited into the CTC CNB account.  Petitioner                  
          included $435,034.98 of this amount in gross income on his 1975             





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