AJF Transportation Consultants, Inc., et al. - Page 21

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                    For the reasons stated below, we hold that Ferrentino has                                     
             not submitted credible evidence of any cash payments made to                                         
             casual labor.                                                                                        
                    Petitioners have presented no documentation to corroborate                                    
             the oral testimony of the above-mentioned witnesses.  AJF did not                                    
             maintain any records of alleged payees who received cash for                                         
             services performed as casual laborers during the 1988, 1989, and                                     
             1990 taxable years.  AJF did not retain the trip sheets or                                           
             delivery manifests which might have verified the existence of                                        
             casual labor.  AJF did not maintain any lists of names of any                                        
             casual laborers, records reflecting casual labor hours worked, or                                    
             records of individual earnings in a given year of any casual                                         
             laborer.  Employment tax returns prepared by Brittain did not                                        
             show casual laborers being paid in cash.  AJF did not maintain                                       
             records of how many alleged casual laborers were paid in cash.                                       
             Finally, AJF did not require receipts from alleged casual                                            
             laborers when they were paid in cash.                                                                
                    A factor which dilutes the credibility of Ferrentino and                                      
             Brittain's testimony is that casual labor was never mentioned                                        
             during audit.  Revenue Agent Kathleen Oswald, who conducted the                                      
             audit of AJF, testified that neither Ferrentino nor Brittain had                                     
             disclosed casual labor expenses during audit.  Had Ferrentino                                        








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