- 3 - FINDINGS OF FACT Some of the facts have been stipulated and are incorporated herein by this reference. Petitioner resided in North Bergen, New Jersey, at the time the petition was filed. A. Trucking Business During the taxable years 1992 and 1993, petitioner owned and operated her own trucking business as a sole proprietor. At the beginning of 1993, petitioner owned two Mack trucks. Petitioner drove at least one of the trucks herself to transport cargo containers for Cappy's Transport, Inc. (Cappy's) on behalf of Goya Foods, Inc., from Goya's processing plant in Secaucus, New Jersey, to Port Newark for shipment overseas.3 Petitioner worked as an independent contractor and was paid according to the number of containers delivered. Petitioner controlled the conditions of her employment, working as little or as much as she pleased. Petitioner failed to maintain adequate books and records of the gross income and expenses of her trucking business. On Schedule C of her 1992 income tax return, petitioner reported gross receipts of $68,145 and net business income of $16,689 from her trucking business. 3 The record does not disclose how or whether the other truck was being used while petitioner was making deliveries for Cappy's, or whether the rate at which the one truck was being driven by petitioner left time for someone else to drive it during the taxable year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011