- 53 -
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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