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as a commission for Diesel Power; $771.17 is reported as a
commission for CTC; and $14,891.74 is recorded as a "cost of
purchase." The 1973 receipts journal also reflects a payment
from Pioneer in the amount of $472.86. This payment was
deposited in the CTC CNB account. Of this amount $283.72 was
recorded in the CTC receipts journal as a commission for Diesel
Power, and $189.14 was recorded as a commission for CTC.
In the notice of deficiency for 1974 respondent determined
an adjustment to income from Pioneer Portec in the amount of
$269.31. The 1974 CTC receipts journal lists receipt of a
payment from Pioneer in the amount of $448.85. This payment was
deposited in the CTC CNB account. The CTC receipts journal
records $269.31 of this payment as commissions for Diesel Power
and $179.54 as commissions for CTC.
In the notice of deficiency for 1975 respondent increased
petitioner's income from Pioneer by $300,090.87. During the
taxable year 1975 Pioneer issued two checks payable to CTC in the
total amount of $400,121.15, both of which were deposited in the
CTC CNB account. The 1975 CTC receipts journal records a total
of $100,030.28 as Pioneer commissions for CTC and a total of
$300,090.87 as Pioneer commissions for Diesel Power. Petitioner
reported on his 1975 income tax return the $100,030.28 recorded
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