Michael S. Palmer - Page 7

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               Petitioner testified that he usually had to pay 12 percent             
          of his compensation to MAP because his worker's compensation                
          insurance policy had expired and MAP allowed him to be covered              
          under MAP's policy.  He testified that he received 12 percent               
          less than the check amount because of the worker's compensation             
          arrangement that he had with MAP.  The checks in evidence show              
          that petitioner cashed them and that they were paid in full.                
          There is no documentary evidence that petitioner gave MAP any               
          money for worker's compensation.                                            
               A comparison of the canceled checks that MAP paid to                   
          petitioner with copies of invoices that petitioner submitted to             
          MAP shows:  (a) Some checks are 12 percent less than the total of           
          the invoices that immediately preceded issuance of the checks,              
          (b) some checks were for the total amount of the invoices that              
          immediately preceded issuance of the checks, and (c) some checks            
          were for more than the total of the invoices that immediately               
          preceded issuance of the checks.  Some of the checks do not                 
          appear to be related to any invoices.  The comparison shows that            
          the differences between the amounts in the invoices and checks              
          were $550.01 for 1992 and $6,197.49 for 1993, much less than 12             
          percent of the invoice amounts.  The differences are considerably           
          less than the amounts respondent allowed.  We conclude that                 
          petitioner has failed to show that he is entitled to deduct 12              








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