- 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 NextLast modified: May 25, 2011