Michael and Patricia Vetrano - Page 5




                                        - 5 -                                         
                                  1991       1992      1993        Total              
             BMAP                                                                     
             Cash                 $73,713   $30,319   $16,981    $121,013             
             Checks, Nonpayroll   21,097    64,824    230,322    316,243              
             Subtotal             94,810    95,143    247,303    437,256              
             Sing-Sing            90        -0-       -0-        90                   
             Gerre Trans          280       470       -0-        750                  
             Richman & Sons       525       -0-       -0-        525                  
             Camden City Probation-0-        -0-      1,035       1,035               
             Total                95,705    95,613    248,338    439,656              

             The above payments are not reported on petitioner’s                      
             separate returns for 1991 and 1992 or petitioners’ joint                 
             return for 1993.  Petitioner maintained no books and                     
             records for his automobile parts business.                               
                  BMAP supplies automobile parts to remanufacturers and               
             rebuilders on a wholesale basis.  It does not sell                       
             automobile parts to the general public.  During the years                
             in issue, BMAP published one or more price lists of the                  
             automobile parts that it would purchase and the amount                   
             that it would pay for each automobile part on the list.                  
             Petitioner obtained automobile parts listed on BMAP’s price              
             list principally from junk yards and delivered them to                   
             BMAP.  BMAP paid petitioner the amount set forth on its                  
             price list for each of the automobile parts that it                      
             received from petitioner.  BMAP did not require petitioner               
             to produce receipts for the automobile parts that he sold                
             to BMAP or to establish his cost in any way.  After                      
             petitioner received a payment from BMAP, either in cash or               






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Last modified: May 25, 2011