- 66 -
which was itemized as "OTHER UNREPORTED". During 1975 or 1976
Morgan issued two checks totaling $200,000 to CTC, which were
recorded on CTC's 1976 receipts journal as commissions for CTC
and deposited in the CTC CNB account. These two checks are not
at issue. Morgan also issued seven checks to Diesel Power
totaling $525,786.48, which were not recorded in CTC's journal
for either 1975 or 1976. These checks were deposited in either
the Diesel Power Bank of America account or the Bank of Teheran
in the name of Diesel Power. Four of the seven Diesel Power
checks were issued by Morgan in accordance with explicit
instructions from petitioner.
In the notice of deficiency for 1977 respondent increased
petitioner's income for "SALES COMMISSIONS D.P.T.C." in the
amount of $179,224.28. Respondent contends that $56,302.97 of
this increase was attributable to commissions for Diesel Power
from Morgan. CTC's 1977 receipts journal reflects receipt from
Morgan of a total of $85,594.63, all of which was deposited in
the CTC CNB account. This amount is allocated in the CTC
receipts journal as $29,291.66 in CTC commissions and $56,302.97
in Diesel Power commissions.
M. Harnischfeger
On July 17, 1972, Harnischfeger International Corporation
S.A. (Harnischfeger) and Diesel Power entered into a distributor
Page: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 NextLast modified: May 25, 2011