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 12
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