- 84 - Respondent increased petitioner's 1977 income from Galion by $57,339.32.19 The 1977 CTC receipts journal lists two payments from Galion. Both payments were deposited to the CTC CNB account. One payment in the amount of $307.52 was allocated $184.51 to Diesel Power commissions and $123.01 to CTC commissions. The other payment in the amount of $57,154.81 was designated refunds/reimbursements. On brief, respondent fails to mention the $184.51 Diesel Power commission. Furthermore, on brief, respondent concedes that the $57,154.81 is a reimbursement. Therefore, the $57,339.32 is no longer at issue. In the notice of deficiency for 1978 respondent increased petitioner's commission income from Galion in the amount of $671,394.73. Respondent now contends that $415,896.98 constitutes unreported commission income to petitioner. The CTC receipts journal for 1978 lists a payment from Galion in the amount of $32,560.36 in the "Other" column. The CTC receipts journal also shows a Galion payment in the amount of $638,894.37. Of this payment $383,336.62 is designated as Diesel Power commissions and $255,557.75 as CTC commissions. 19There is a discrepancy between the stipulated figure of $57,339.32 and the notice of deficiency. The notice of deficiency shows $57,154.81 as the adjustment to 1977 income. We accept the stipulated figure.Page: Previous 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 Next
Last modified: May 25, 2011