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$243,665.65. In the amendment to answer respondent increased
this figure by an additional $144,812.48. During 1976, at the
direction of Mrs. Conway, Ingersoll-Rand deposited commissions
totaling �5,494.40 into the Zand FNCB London account. At the
average monthly exchange rate for March 1976, this was equivalent
to $10,688.05. (International Financial Statistics, March 1976.)
In a sworn affidavit dated February 26, 1981, handwritten by one
of the IGOS shareholders, Hossein Shirazi, (Mr. Shirazi), stated
that during both 1976 and 1978 IGOS paid $120,000 to petitioner
for Ingersoll-Rand commissions. Mr. Shirazi was not a witness in
this proceeding. No income from IGOS was reported on
petitioner's 1976 return. Petitioner reported $120,000 as income
attributable to IGOS on his 1978 Federal income tax return.
Respondent now concedes a portion of the earlier positions and
contends only that petitioner failed to report $130,769.02 in
1976 commissions from Ingersoll-Rand. This amount consists of
the alleged $120,000 distribution from IGOS described by Mr.
Shirazi in his affidavit and the equivalent of $10,769.02
deposited in the form of British pounds in the Zand FNCB London
account.
K. Morgan
Although there was no written agreement or contract between
Morgan and Diesel Power, petitioner, or CTC, there apparently was
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