J.J. Zand - Page 270

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          in the CTC CNB account.  The CTC receipts journal for 1973                  
          records commissions from Galion for CTC in the amount of                    
          $113,865.90 and for Diesel Power in the amount of $170,798.84.              
               The notice of deficiency for 1974 increased petitioner's               
          commission income from Galion by $60,129.43.  During the taxable            
          year 1974 Galion issued checks payable to CTC in the total amount           
          of $100,215.71, all of which were deposited in CTC's CNB account.           
          The 1974 CTC receipts journal records the amount of $40,086.28 as           
          CTC commissions and $60,129.43 as Diesel Power commissions.                 
               In the notice of deficiency for 1975 respondent increased              
          petitioner's "Per books" income from Galion by $1,202,188.66 and            
          "Other" income by $3,780.  For the taxable year 1975 Galion                 
          issued checks payable to CTC in the total amount of                         
          $1,870,239.25.  These checks were deposited to CTC's CNB account.           
          Of this total amount $221,069.80 constituted reimbursement to CTC           
          for costs of purchases.  This amount was not included by                    
          petitioner as cost of goods sold on his 1975 return.16  The 1975            
          CTC receipts journal records $447,231.27 as commissions to CTC.             
          The remaining $1,202,188.1817 was listed as commissions to Diesel           

          16 Thus, respondent made no adjustment to petitioner's total Schedule C     
          income for $221,069.80 in the notice of deficiency for 1975.                
          17 We note that the stipulation states that the total amount included in    
          income was $447,231.27 and that, consequently, the net total of the deposits
          not included in petitioner's income, as listed in the stipulation, is       
          $1,201,938.18.  We are unable to identify from the 1975 CTC cash receipts   
          journal two of the deposits listed in the stipulation as having been included






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