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$197,079.14.15 During 1974 $1,669.64 in commissions from
Ingersoll-Rand was deposited to the IGOS CNB Columbus account.
These payments were not included in the CTC receipts journal.
Respondent now concedes that petitioner is not liable for any
increased commission income from Ingersoll-Rand except to the
extent that he withdrew funds from the Bank of America account.
In the notice of deficiency for 1975 respondent increased
petitioner's 1975 commission income from Ingersoll-Rand by
$781,078.02. During 1975 Ingersoll-Rand issued checks or made
wire transfers to the Diesel Power Bank of America account in the
total amount of $781,078.02. In the amendment to answer
respondent increased this amount by an additional $691,602.46.
This additional figure was based in part upon deposits made by
Ingersoll-Rand to the IGOS CNB Columbus account and the Banque de
Paris, and payments mailed directly to Diesel Power. The
additional figure is also based in part upon an alleged 1975
deposit to the Zand FNCB account in the amount of $197,513.88.
Respondent now concedes all but the $197,513.88 that was
allegedly deposited to the Zand FNCB account.
In the notice of deficiency for 1976 respondent increased
petitioner's commission income from Ingersoll-Rand by
15 We are unable to explain the reason that this figure differs slightly
from the stipulated deposit.
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