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July 17, 1978, letter accepting termination, petitioner stated
that he agreed with Pioneer that "until such time as we have
created a substitute for Diesel Power, which has ceased to exist
and operate as the company that I created in 1958, you had no
choice but to cancel our agreement." He further stated: "I will
be creating a representation outlet for your line in Iran * * * .
We are not about to leave you without representation as we
continue to feel obligated to serve your interests in Iran." In
a letter dated May 18, 1979, petitioner represented to Pioneer
that Diesel Power had no interest in or right to a sales
commission of $121,813.43 earned on a particular order; that CTC
was entitled to this commission; and that CTC would hold Pioneer
harmless against any claim that Diesel Power might assert with
regard to this commission. Along with a letter 1 week later,
Pioneer sent a commission check to petitioner and expressed
regret that this might be the last business transaction between
Pioneer and CTC.
P. Payments by Pioneer
In the notice of deficiency for 1973 respondent increased
petitioner's income from Pioneer in the amount of $1,440.47. The
1973 CTC receipts journal lists a payment from Pioneer of
$16,838.31. This payment was deposited in the CTC CNB account.
$1,156.75 of this payment is recorded in the CTC receipts journal
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