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to bank accounts in the name of Diesel Power in the total amount
of $681,783.24. These payments were not recorded in the 1976 CTC
cash receipts journal.
In the notice of deficiency for 1977 respondent determined
additional income for "Sales commissions D.P.T.C.", $22,545.46 of
which was attributable to commissions from Clark. During 1977
Clark issued checks payable to Diesel Power or to Diesel Power
bank accounts in the total amount of $38,569.34. None of this
amount was recorded on CTC's cash receipts journal. The journal
does list receipt from Clark of $22,723.98, all of which was
deposited in the CTC CNB account. Of this amount $14,013.71 was
allocated to Diesel Power commissions and $8,710.27 to CTC
commissions.
In the notice of deficiency for 1978 respondent determined
additional income from Clark in the amount of $36,796.41. The
1978 CTC receipts journal reflects a total of $21,831.24 received
from Clark, $6,640.14 of which was allocated to CTC and
$15,191.10 of which was allocated to Diesel Power.
U. Miscellaneous Commissions/Goodyear
Petitioner, CTC, and Diesel Power also had relationships
with many other companies resulting in the payment of numerous
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