J.J. Zand - Page 241

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          for the above amounts was $1,142,908.40, which was not included             
          in petitioner's 1976 income.11                                              
               There also were payments from GM in 1976 that were not                 
          recorded in the CTC receipts journal.  On February 3, 1976, a               
          deposit from GM was made to the Zand FNCB London account in the             
          amount of �38,585.50.  Neither this deposit nor its dollar                  
          equivalent was recorded as a receipt on the CTC receipts journal.           
          At the average monthly exchange rate for February 1976,                     
          �38,585.50 was equivalent to $78,058.47.  Although the notice of            
          deficiency lists this as an "Deposit to F.N.C.B." of $38,585.50             
          in U.S. currency, in the amendment to answer respondent asserts             
          that there was a increased deficiency with respect to this                  
          deposit to reflect the correct amount in U.S. currency.  On April           
          27, 1976, a deposit was made by GM to the same account in the               
          amount of �34,980.77.  Neither this deposit nor its dollar                  
          equivalent was recorded as a receipt in the CTC receipts journal.           
          At the average monthly exchange rate for April 1976, this deposit           
          was equivalent to $64,644.76.  Although this deposit was listed             
          in the notice of deficiency as $34,980.77 in the amendment to               
          answer respondent asserts that there was an increased deficiency            
          with respect to this deposit to reflect the correct amount in               
          U.S. currency.                                                              

          11 We are unable to explain the difference between this figure and the      
          amount on the notice of deficiency for "Per Books Unreported" income of     
          $1,112,550.51.                                                              





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