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occasions in 1977 Mrs. Conway, on behalf of CTC, sent letters to
Harnischfeger requesting commission payments payable to Diesel
Power.
N. Payments by Harnischfeger
In the notice of deficiency for 1974, respondent increased
petitioner's "per books unreported" income from Harnischfeger by
$525.41. No payments from Harnischfeger are reflected in the CTC
receipts journal. That journal does reflect a payment from a
company called Parker Hannifin (allegations pertaining to which
will be discussed later under "Miscellaneous Companies") in the
amount of $875.68. Of this payment $525.41 was recorded as a
commission to Diesel Power, and $350.27 was listed as a
commission to CTC. This payment from Parker Hannifin was
deposited in the CTC CNB account. Respondent proposes to
increase petitioner's income from Parker Hannifin by an amount
which apparently does not include this payment. The parties do
not address respondent's 1974 "per books" income from
Harnischfeger in their briefs, nor do they explain why respondent
alleges an amount from Harnischfeger that is equivalent to the
amount of a stipulated payment from Parker Hannifin.
In the notice of deficiency for 1975 respondent increased
petitioner's income from Harnischfeger by $78,000. In March
1975, a bill for $130,000 in commissions with petitioner's
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