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Power. Respondent now claims that only the $1,201,938.20 is at
issue for 1975, thus apparently conceding the alleged "Other"
income in the notice of deficiency.18
In the notice of deficiency for 1976, respondent increased
petitioner's "Per books" income from Galion by $12,845.78 and
"Other" income by $391,286.34. Respondent now asserts that
$390,843.54 is at issue. During the taxable year 1976, Galion
paid Diesel Power a total amount of $390,843.54. These payments
were deposited in the Diesel Power Bank of Teheran account and
were made pursuant to letters from CTC to Galion requesting the
payments. None of these payments was recorded in the CTC
receipts journal for 1976. Petitioner did not include in his
1976 gross income any portion of the $390,843.54. On June 24,
1976, Galion made a payment to Diesel Power in the amount of
$6,000, payable to the Diesel Power Bank of Teheran account.
There is no record of this amount in CTC's receipts journal for
1976. Respondent appears to have conceded the adjustment in the
notice of deficiency with respect to the $6,000 payment.
in income; therefore, we are unable to ascertain whether the specific amounts
listed in the stipulation are correct, but we assume for our findings that
they are and that there was an error in addition. Because the total amount
included in income is $250 less than indicated in the stipulation, the total
amount not included is $250 higher.
18 We are unable to determine why the amount attributed to Diesel Power
on the CTC receipts journal of $1,202,188.18 differs from the amount at issue
according to respondent's brief by $250. We assume that respondent meant to
use the "Per books" figure in the notice of deficiency.
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