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Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
At the time the petition was filed, petitioner resided in
Houston, Texas.
Prior to and during the years in issue, petitioner operated
a "wear lining" business as a sole proprietorship, in which he
developed and sold linings used in pneumatic handling systems
that pulverize and transfer coal into coal-burning industrial
boilers, primarily in power plants. Petitioner visited customers
in the north central and northeastern United States to solicit
orders for such wear linings, arranged for their manufacture by a
third party, and subsequently supervised installation of the
linings at a customer's plant. The conduct of petitioner's
business required extensive travel, which petitioner estimated at
60,000 to 80,000 miles per year.
For recordkeeping in his wear lining business, petitioner
kept a copy of the invoices issued to a customer when an order
was placed and then attached a copy of the check when payment was
received on the invoice. Petitioner kept separate files for
invoices awaiting payment and for paid invoices. It was from
these invoices that petitioner calculated the gross receipts from
the wear lining business reported on Schedule C of his 1990 and
1991 returns. He did not maintain any ledger or journal with
respect to gross receipts.
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