- 58 -
In the notice of deficiency for 1974 respondent also
increased petitioner's income from IMICO/IMISS by $581.27. The
CTC receipts journal for 1974 reflects a payment from IMICO/IMISS
of $16,468.68, which was deposited in the CTC CNB account. Of
this amount, $387.51 was recorded as a commission for CTC,
$581.27 was recorded as a commission for Diesel Power, and
$15,499.90 was recorded as a purchase.
In the notice of deficiency for 1975 respondent increased
petitioner's income from SEDCO by $54,080.33. The CTC receipts
journal for 1975 reflects payments from SEDCO in the total amount
of $665,881.63, which were deposited in the CTC CNB account.
That journal records $36,053.57 as commissions to CTC, $54,080.33
as commissions to Diesel Power, and $575,747.73 as purchases.
In the notice of deficiency for 1975 respondent also
increased petitioner's income from Stewart & Stevenson by
$8,887.73, which consists of $7,409.42 in "per books unreported"
income and $1,478.31 in "other unreported" income. The CTC
receipts journal for 1975 reflects receipt in 1975 of a total of
$12,349.04 from Stewart & Stevenson, which was deposited in the
CTC CNB account. This amount was recorded in the CTC receipts
journal as a total of $4,939.62 in commissions for CTC13 and a
13 We note that respondent alleges in the proposed findings of fact that
petitioner reported $3,461.31 of the total amount received from Stewart &
Stevenson during 1975, but we have found that the CTC books attributed
$4,939.62 to CTC.
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