- 4 -
Yet, he admitted at trial that his endorsement was on the back of
a number of checks issued to him by Village Auto Electric during
1993 and stated in his first amended petition as one of the facts
upon which he based his case that:
While Village Auto Electric, Patrick Obrien [sic]
or Arctic Auto Air Electric had the right to tell the
Petitioner what to do Village Auto Electric, Patrick
Obrien [sic] or Arctic Auto Air Electric did not have
the right to tell the Petitioner how to accomplish his
tasks. Village Auto Electric, Patrick Obrien [sic] or
Arctic Auto Air Electric had to rely upon the
Petitioner's knowledge and experience.
Respondent's revenue agent, Shelby Bare, testified that
respondent relied upon payer information returns which were
received under the Information Returns Program (IRP) in making
the determinations contained in the statutory notices of
deficiency issued to petitioner in this case. Respondent
submitted transcripts from his IRP master file which list the
payers which reported payments to petitioner during 1992, 1993,
and 1994.
Based on the record, we find that petitioner has failed to
prove any error in respondent's determinations on this issue.
He introduced no credible evidence which persuades us that the
amounts of income reported on the information returns received by
respondent were inaccurate. On cross-examination, petitioner was
specifically asked whether he received the amounts determined by
respondent in the statutory notices of deficiency for the years
in issue from Village Auto Electric, Patrick Steve O'Brien, Polar
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011