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bears a date in 1988, a year not in issue.1 The job names shown
on five of the seven sheets bear no apparent relation to the
project or account names shown on the copies of checks used to
calculate petitioner's stipulated gross receipts for the years in
issue. Moreover, there is no evidence that the bid sheets were
ever submitted to, or accepted by, any general contractor.
Therefore, it is not clear that the bid sheets relate to actual
jobs performed by petitioner during the years in issue.
Even if the bid sheets represent any actual jobs, there is
no evidence that the profit factors in the sheets represent the
actual profit realized by petitioner from those jobs. There is
no evidence that Mr. Sager compared any of the bid sheets with
the financial results of any job.
Finally, even if the bid sheets represented petitioner's
actual profits from actual jobs, there is no evidence that the
sheets represented a reliable sample of the jobs performed by
petitioner during the years in issue. The sheets--which were
obtained from petitioner--represent only seven jobs; yet Mr.
Sager used them to attempt to estimate 6 years of petitioner's
income.
For all these reasons, we are not persuaded that Mr. Sager's
estimates of petitioner's income based on the bid sheets bear any
relation to the actual amount of profit or taxable income
1 Of course, a job bid for in 1988 could have been performed
in a later year, but there is no evidence of this in the record.
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