- NEXTRECORD -
Also noteworthy is the fact that petitioner was placed on
academic suspension following the spring semester of 1990 and did
not return to the University of Houston until the fall semester
of 1991. At that time he enrolled in only two courses for a
total of 7 credits. Thus, petitioner's academic endeavors in
1991 would hardly have impeded his income-producing activity as a
barber. This is especially evident from the fact that in 1989,
when petitioner was enrolled in 4 courses for a total of 13
credits during the spring semester and 3 courses for a total of
10 credits during the fall semester, petitioner was capable of
earning as a barber (according to his credit application with
Metropolitan) "take-home" pay of $350 per week.
During the course of the examination, petitioner represented
that he maintained a wall calendar at the barber shop that he
used to keep track of appointments and to record income. He
further represented that the current month of the calendar was
not retained after month's end. At trial, petitioner denied
making these representations. When confronted with his written
Protest, which referred to an "appointment book",13 petitioner
responded as follows:
13 The pertinent part of the Protest stated as follows:
The taxpayer maintained an appointment book for his
customers and to list the income earned from his
customers. The taxpayer then reported the income on
his tax return.
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