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total of $7,409.42 in commissions for Diesel Power. The parties
presented no evidence concerning the $1,489.31 of alleged "other
unreported" income in the notice of deficiency.
In the notice of deficiency for 1976 respondent made an
adjustment to petitioner's income from IMICO/IMISS of $1,727.27.
The CTC receipts journal for 1976 reflects receipt during 1976 of
payments from IMICO in the total amount of $30,236.10, which were
deposited in the CTC CNB account. The journal records $1,151.53
of this amount as commissions for CTC, $1,727.27 as commissions
for Diesel Power, and $27,357.30 as purchases.
In the notice of deficiency for 1976 respondent also
proposes to increase petitioner's income from SEDCO by
$92,058.39. The CTC receipts journal for 1976 reflects a total
amount received from SEDCO of $678,941.33, which was deposited in
the CTC CNB account. That journal records $61,372.27 as
commissions to CTC, $92,058.39 as commissions to Diesel Power,
and $525,510.67 as purchases.
In the notice of deficiency for 1978 respondent increased
petitioner's income from IMICO by $942.02, from SEDIRAN by
$111,955.01, and from SEDCO by $38,033.49. CTC's 1978 receipts
journal attributes no commissions from IMICO, SEDIRAN (apparently
an affiliated company), or SEDCO to Diesel Power. Instead, all
are attributed to CTC commissions or "purchases".
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