- 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.Page: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
Last modified: May 25, 2011