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J. Payments by Ingersoll-Rand
In the notice of deficiency for 1973 respondent increased
petitioner's income from Ingersoll-Rand by $48,222.04.14 During
1973 Ingersoll-Rand made payments of $41,129.39, which were
deposited in the Diesel Power Bank of America account.
Ingersoll-Rand also deposited �174.54 at Mrs. Conway's
instruction in the Zand FNCB London account in September 1973.
In 1973 the CTC receipts journal reflects receipt of payments of
$976.86 from Ingersoll-Rand. These payments were recorded as
commissions to Diesel Power of $586.12 and commissions to CTC of
$390.74. In 1973 $976.86 was deposited in the CTC CNB account.
Respondent concedes that petitioner is not liable for any
increased 1973 commission income from Ingersoll-Rand except to
the extent that petitioner withdrew funds from the Diesel Power
Bank of America account.
In the notice of deficiency for 1974 respondent increased
petitioner's income from Ingersoll-Rand by $197,259.65. During
1974 Ingersoll-Rand issued checks or made wire transfers to the
Diesel Power Bank of America account in the total amount of
14 We are unable to ascertain the basis for this figure originally
determined by respondent.
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