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and 1992 Federal income taxes in the amounts of $5,256 and
$5,169, respectively.
The issue for decision is whether petitioners underreported
gross receipts from a newspaper delivery service business
conducted by Ernest L. Newsome during 1991 and 1992.
Background
Some of the facts have been stipulated, and they are so
found. At the time of the filing of the petition, petitioners
resided in Fort Worth, Texas. References to petitioner are to
Ernest L. Newsome.
Starting as a child, and for a number of years prior to the
years in issue, petitioner had been employed, in various ways, as
a newspaper carrier or delivery person. He began delivering
newspapers for the Fort Worth Star Telegram (the Star Telegram)
sometime in the early 1980's. During the years in issue he
delivered newspapers for the Star Telegram on an independent
contractor basis. Using the cash receipts and disbursements
method of accounting, petitioner reported the income earned and
the expenses incurred in the operation of his newspaper delivery
service business on Schedules C for the years 1991 and 1992.
During the years in issue, the Star Telegram published
morning and evening editions from Monday through Friday, and a
single edition on Saturdays and Sundays. Consequently,
petitioner delivered newspapers to his customers twice a day
during the week and once per day on Saturdays and Sundays.
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