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transported within the period, the gross amount earned with
respect to the loads transported within the time period, and the
amount deducted from the gross amount earned for worker’s
compensation, brokerage commission, liability insurance, trailer
rental, collision insurance, and fuel costs. Each ledger sheet
devoted one line to a driver. There are columns along the top of
each ledger sheet that include information such as the gross
amount received from IMC or other companies and the expenses or
brokerage commission that was deducted by petitioner.
Because each payment a driver received for transporting a
load(s) was reduced by some or all of these expenses, the checks
received by the drivers from petitioner were for net proceeds.
For example, during the week of January 17, 1994, driver number
12 hauled 16 loads for IMC. IMC paid petitioner $1,136.90
($816.90 for the loads that driver number 12 transported plus a
$320 fuel service charge). Petitioner then deducted $110 for
worker’s compensation, $57 for its brokerage commission, $135.50
for liability insurance and $242.65 for fuel. Petitioner issued
a check to driver number 12 for $591.75.
The amounts that petitioner deducted from the drivers’
checks for various expenses were marked up from the actual
expenses that petitioner incurred. Thus, in the example above,
the worker’s compensation insurance, the liability insurance, and
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