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organizations, respondent determined that there was cash ($54,416
for 1993 and $106,038 for 1994) available for distribution to
Messrs. Fields, Bullock, Sharpe, and Peacock, computed as follows:
1993 1994
Net income $119,957 $218,074
Less: payments to workers (62,841) (101,010)
Less: payments to charities (2,700) (11,025)
Net income available for
distribution 54,416 106,039
The Bullocks’ Van Pool Activity
During 1993 and 1994, and for approximately 8 years prior
thereto, Mr. Bullock operated a van pool in which he provided
transportation to and from work to a number of individuals in
exchange for a predetermined fee. Mr. Bullock operated the van
pool between his residence in Portsmouth, Virginia, and both the
Naval Air Station in Norfolk, Virginia, and the Newport News
Shipyard in Newport News, Virginia.
Mr. Bullock owned the van used in the van pool activity. He
drove the van from Portsmouth to Norfolk, where he was employed as
a supply clerk. Another person drove the van from Norfolk to the
Newport News Shipyard. This other person was permitted to ride for
free.
Other than canceled checks for expenses paid out of Mr.
Bullock's personal checking account, Mr. Bullock did not maintain
contemporaneous records of the expenses incurred in operating the
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Last modified: May 25, 2011