- 93 -
commissions. Petitioner reported the $1,352.75 on his return,
but did not report the balance of the $1,011,451.47. During 1975
Clark also deposited �1,095.63, equivalent to $2,622.94,21 into
the Zand FNCB London account. This deposit was not recorded on
the CTC cash receipts journal. During 1975 Clark also issued
payments directly to Diesel Power or to a Diesel Power bank
account in the total amount of $59,823.83. These payments were
not recorded in the 1975 CTC receipts journal.
In the notice of deficiency for 1976 respondent increased
petitioner's income from Clark by $134,086.23 "Per books" income
and $253,173.06 "Other" income. During 1976 Clark paid CTC
$19,754.24. The 1976 CTC receipts journal allocates $11,852.54
to Diesel Power commissions and $7,901.70 to CTC commissions.
During 1976 Clark paid Diesel Power a total of $674,658.88. Of
this amount $455,125.68 was deposited in the CTC CNB account.
The remaining $219,533.20 was not recorded in the 1976 CTC
receipts journal. The 1976 CTC journal also lists $81,489.53 as
CTC commissions and $122,234.29 as Diesel Power commissions.
During 1976 Clark also made payments directly to Diesel Power or
21 Respondent's answer asserted that Clark paid $1,095.63 to petitioner
in 1975, but in the amended answer asserted that this was the figure in
pounds, not dollars.
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