J.J. Zand - Page 240

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               In the notice of deficiency for 1976 respondent made                   
          adjustments in connection with payments from GM for "per books              
          unreported" income of $1,112,550.51, "other" income of                      
          $34,980.77, a "Deposit to F.N.C.B." of $38,585.50, and additional           
          other income of $34,377.70.10  During 1976 a portion of the                 
          commissions paid by GM to CTC was equal to a total amount of                
          $1,482,524.70.  These payments were deposited to the CTC CNB                
          account.  The 1976 CTC receipts journal allocated $385,343.07 of            
          this amount to CTC as commissions and $1,062,803.40 of this                 
          amount to Diesel Power as commissions.  The remaining $34,377.70            
          was noted on the CTC cash receipts journal as "Trans" and is                
          equivalent to an amount petitioner sent to the Amelia Corporation           
          in 1976.  GM also issued a commission check in 1976 payable to              
          CTC in the amount of $11,581.51, and four checks to Diesel Power            
          in the total amount of $121,926.94, for a total of $133,508.45.             
          On CTC's cash receipts journal, these checks were allocated                 
          $53,402.77 to CTC and $80,105.08 to Diesel Power.  The total                
          amount allocated to Diesel Power on CTC's 1976 receipts journal             






          10 We are unable to explain the $30,357.89 difference between the amount    
          recorded in the CTC receipts journal as attributable to Diesel Power and the
          amount alleged to be "per books unreported" by respondent in the notice of  
          deficiency.  Part of adjustment a.3. for 1976 also proposes an adjustment for
          commission expense in the amount of $361,971.26.                            





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