7 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 12Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011