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as CTC commissions. Petitioner did not report on his 1975 income
tax return the $300,090.87 recorded as Diesel Power commissions.
In the notice of deficiency for 1976 respondent increased
petitioner's income from Pioneer by $876,850.39 in "Per books"
unreported income and $232,640.80 in "Other" unreported income,
for a total of $1,109,491.19. During the taxable year 1976
Pioneer issued checks payable to CTC in the total amount of
$1,447,634.21. All of these checks were deposited in the CTC CNB
account. The 1976 CTC receipts journal records a total of
$570,783.82 as Pioneer commissions to CTC and $876,850.39 as
Pioneer commissions to Diesel Power. Also during 1976, there was
a wire transfer from Pioneer to the Diesel Power Bank of Teheran
account in amount of $232,615.80, with an additional $25 listed
on the check order for "Airmail or cable charge" and
"Commission". Respondent concedes the additional $25. This wire
transfer was not recorded in the 1976 CTC receipts journal.
In the notice of deficiency for 1977 respondent increased
petitioner's income from Pioneer by $12,201.80. The 1977 CTC
receipts journal lists receipt from Pioneer of $20,336.34, which
was deposited to the CTC CNB account. The journal records
$12,201.80 as commissions to Diesel Power and $8,134.54 as
commissions to CTC.
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