- 69 - 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.Page: Previous 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 Next
Last modified: May 25, 2011