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matter was equally conflicting. Suffice it to say that the
record does not support a finding of a per-unit compensation
schedule used by petitioners when compensating their sons.
Petitioner Bui testified that her sons maintained records of
their own work activity and that all compensation paid to her
sons was based solely on those records. When it came time to be
paid, each son simply informed petitioner Bui of the work he had
performed, and petitioner Bui in turn paid cash to that son.
Petitioner Bui further testified that she prepared Forms 1099-
MISC for each son for both taxable years at issue based on the
records maintained by her sons.
Petitioner Bui's oldest son, Tri, did not testify at trial;
however, her other three sons, Dung, Duy, and Thinh, did testify.
The sons' testimony regarding the recordation of their work
activity is ambiguous and conflicting. Dung testified that he
kept track of the work he performed in a multitude of ways. He
frequently relied upon invoices for his record, but occasionally
he recorded his activity on pieces of paper. Still other times,
he simply made mental notes of the work he performed. Dung
further testified that he did not submit his records to
petitioner Bui for payment, rather he simply told her what he had
done and was paid accordingly. Dung also testified that he
discarded the records reflecting his work activity.
Dung's testimony with regard to what happened to his work
activity records is inconsistent. Dung first testified that he
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