- 82 -
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
Page: Previous 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 NextLast modified: May 25, 2011