Eddie Stricklin - Page 4

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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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