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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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