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signature on CTC stationery was sent to Harnischfeger asking that
payment be sent to CTC. In April 1975, Harnischfeger issued a
check to CTC in the amount of $130,000, which was deposited into
the CTC CNB account. This amount was recorded in CTC's 1975 cash
receipts journal as $52,000 in commissions to CTC and $78,000 in
commissions to Diesel Power. Neither CTC nor petitioner included
the $78,000 amount attributed to Diesel Power in income for 1975.
In the notice of deficiency for 1976 respondent increased
petitioner's income from Harnischfeger by $33,809.71. During
1976 Harnischfeger, upon instructions from a CTC employee, issued
checks payable to CTC in the total amount of $56,349.52. These
checks were deposited into the CTC CNB account. They were
recorded as commissions for CTC of $22,539.81 and for Diesel
Power of $33,809.71.
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. Of this amount $56,158.59 was
attributable to commissions for Diesel Power from Harnischfeger.
The CTC receipts journal for 1977 lists receipt from
Harnischfeger of a total amount of $93,597.66, which was
deposited into the CTC CNB account. That journal allocated
$37,439.07 as commissions for CTC and $56,158.59 as commissions
for Diesel Power.
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