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journal. In the notice of deficiency for 1973 respondent also
increased petitioner's income from IMICO by $7,752.15. During
1973 the CTC receipts journal reflects receipts from IMICO or
IMISS12 in the total amount of $52,777.81. This amount was
deposited in the CTC CNB account and was allocated as $5,168.06
in commissions to CTC, $7,752.15 in commissions to Diesel Power,
and $39,857.60 in costs of purchases.
In the notice of deficiency for 1974 respondent increased
petitioner's income from SEDCO by $64,394.40. During 1974 SEDCO
issued checks payable to CTC in the total amount of $744,226.49,
all of which were deposited in the CTC CNB account. This total
amount was recorded in the 1974 CTC receipts journal as
$42,929.60 in commissions for CTC, $64,394.40 in commissions for
Diesel Power, and $636,902.49 in purchases.
In the notice of deficiency for 1974 respondent also
increased petitioner's income from Stewart & Stevenson by
$13,002.61. The CTC receipts journal for 1974 lists payments
from Stewart & Stevenson of a total amount of $21,671.01, which
was deposited into the CTC CNB account. This Stewart & Stevenson
amount was allocated in the CTC receipts journal as $8,668.40 in
commissions to CTC, and $13,002.61 in commissions to Diesel
Power.
12 Although we have been unable to identify the relationship, we assume
that IMISS is an affiliate of IMICO.
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