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the respective amounts of $98,670.65, $138,220.40, and $102,480
in 1988, 1989, and 1990, respectively.
Petitioners claim that Brittain's Report accurately computed
the number of hours attributable to the alleged casual labor by
comparing AJF's payroll figures to the billing invoices for
services rendered by AJF to J.C. Penney. Brittain used the
billing invoices to determine the total number of manpower hours
AJF employees actually rendered to J.C. Penney. She used AJF's
payroll records to determine the number of manpower hours
attributable to AJF employees as reflected on the payroll
records. The Report attributed the difference between the
payroll and billing invoice figures to "casual labor". For
example, the Report concludes that for the second quarter of 1988
the manpower hours attributable to casual labor totaled 2464.3
hours. The Report derived this figure by subtracting 41,670.3
manpower hours shown on AFJ's payroll records from the manpower
hours of 44,134.6 shown on the invoices.
Brittain's Report is laced with flaws. For purposes of
computing payroll manpower hours, the Report treated all
employees listed in the Report as drivers, even though they had
helpers who were also on the payroll. The record indicates that
a delivery truck required two people: a driver and a helper.
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