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affidavit. In that affidavit, petitioner declared that he
received cash payments totaling $399,435.50 from Mr. Hall. The
affidavit does not mention any payments made "through" Mr. Hall
to some unknown third parties, as petitioner now contends.
Furthermore, the record contains no documentation or other
corroborating evidence regarding these alleged expenses.
Moreover, petitioner does not explain how these expenses
related to the income he received from Mr. Hall. Petitioner
testified that the work he performed for Mr. Hall included the
estimation and preparation of bids.8 We find it implausible that
the nature of this work would require petitioner to share
expenses with Mr. Hall or to make capital expenditures for
vehicles and equipment.
Petitioner contends that he "felt uncomfortable" estimating
his income on his Federal income tax returns because, in his
view, "falsely representing the amount of such income was worse
than making no representation at all." However, in order to
extend the time to file his Federal income tax returns,
petitioner filed a Form 4868 in each of the years in issue in
8On direct examination regarding the nature of the payments
he received from Mr. Hall, petitioner testified as follows:
A. I did estimating type work, helping him prepare his
things.
Q. Helping him prepare what things?
A. His bids and prices of what he needed to do.
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