J.J. Zand - Page 279

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          receipts from Clark were $58,833.83.  CTC endorsed these checks             
          and all were deposited in the CTC CNB account.  The CTC 1973 cash           
          receipts journal records $35,300.29 of the total payments from              
          Clark as "DPTC" commissions and $23,533.54 as "Caspian"                     
          commissions.                                                                
               In the notice of deficiency for 1974 respondent increased              
          petitioner's income from Clark by $39,972.49 "Per books" income             
          and $17,925.58 for "Other" income for a total of $57,898.07.  In            
          the amendment to answer respondent asserts that there were Clark            
          payments deposited to the Zand FNCB London account of �17,141.67,           
          equivalent to $39,837.99.  During 1974 Clark issued total                   
          payments to CTC of $8,621.92 and to Diesel Power of $57,991.50,             
          or a total of $66,613.42.  Mrs. Conway had requested that at                
          least some of the payments be made to the CTC CNB account, and              
          they were so deposited.  CTC's 1974 cash receipts journal lists             
          $26,645.37 of this amount as CTC commissions and $39,968.05 of              
          this amount as Diesel Power commissions.  Clark also paid the               
          following amounts that were not reflected on the CTC receipts               
          journal, and not reported as income by petitioner in 1974:                  
               Amount         Account to which deposited                              
               $12,175.75     Zand FNCB                                               
               10,949.35      Zand FNCB                                               









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