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1976 14,030
1977 19,152
1978 18,300
1979 18,362
Similarly, during the years at issue, Besco paid petitioner the
following amounts in connection with its sales to the paint
department:
Year Amount
1980 $21,315
1981 25,377
1982 19,274
1983 17,642
Besco reported all payments to the Internal Revenue Service
(IRS) on Forms 1099 Misc. Petitioner, in turn, reported receipt
of the above amounts on his returns for each respective taxable
year.
In 1974, Tubre had a meeting with an ASI vice president
named Clark. During the course of that meeting, Clark instructed
Tubre to cease paying ASI employees for their involvement in "in
the yard" activities. Tubre informed petitioner, Kahn, and
Steiner of his conversation with Clark. He also told petitioner
that Besco intended to comply with Clark’s directive. The
payments, however, continued despite Tubre's reservations.
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