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that the income received from Ray Cossette Trucking, Citywide
Constructing, Bork Transport, and Weston Corporation in 1989 and
from Dana Transport in 1990 constituted W-2 income that was not
reported. In addition to the W-2 income, respondent determined
that petitioner had Schedule C gross receipts of $14,790 in 1989
and $34,320 in 1990 that were not reported. The deficiency
notice further determined that petitioner was liable for self-
employment taxes on the Schedule C gross receipts in the amounts
of $1,926 for 1989 and $4,849 for 1990. The notice did not
identify the source of the Schedule C gross receipts, or
otherwise disclose how these income determinations were made.
Petitioner admits receiving all of the W-2 income determined
in the notice of deficiency. However, petitioner disputes the
$14,790 and $34,320 amounts determined by respondent to be
Schedule C gross receipts in 1989 and 1990, respectively.
Petitioner has stipulated that he worked for Lighthouse as a
truck driver during these years and received income as a result,
but contends that he received less than the amounts determined by
respondent to be Schedule C gross receipts. Specifically,
petitioner testified that he received approximately $3,000 by
check from Lighthouse in 1989, but that Lighthouse's checks
thereafter began to bounce, and he insisted on payment in cash
for the rest of 1989 and all of 1990. These payments were made
on a commission basis by which petitioner received a percentage
of the price paid to Lighthouse for each truckload or delivery he
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