- 92 -
1,124.55 Zand FNCB
50,658.25 Mailed to Diesel Power or a Diesel Power
account
In the notice of deficiency for 1975 respondent increased
petitioner's income from Clark by $173,185.21 "Per books" income
and $1,009,165.22 "Other" income for a total of $1,182,350.43.
Respondent asserts in her answer that Clark paid petitioner
$1,095.63 in 1975. In the amendment to answer respondent asserts
that Clark paid petitioner �1,095.63, equivalent to $2,622.94 in
1975. During 1975 Clark issued checks to CTC in the total amount
of $285,260.12. These checks were deposited to CTC bank
accounts. In the 1975 CTC receipts journal $114,104.04 of the
total amount is recorded as CTC commissions, all of which was
included in CTC's 1975 income. The remaining $171,156.08 was
recorded as Diesel Power commissions. CTC did not include this
amount in income. During 1975 Clark issued checks to Diesel
Power in the total amount of $1,011,451.47. One of these checks,
in the amount of $3,381.88, was deposited to the CTC CNB account.
The remaining checks were deposited, at least in part, to Diesel
Power accounts at the Banque de Paris, Bank of America, or CNB at
CTC's request. On the 1975 receipts journal $1,352.75 is
recorded as CTC commissions and $2,029.13 as Diesel Power
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