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As to petitioners’ position that “Mr. Vetrano had
no unreported income from BMAP”, petitioners make three
assertions. First, they acknowledge that Mr. Vetrano
received payments from BMAP in the amounts determined by
respondent, but they assert that “these payments were not
income to him but advances made by his employer to purchase
used auto parts on behalf of his employer.” They also
suggest that Mr. Vetrano received the payments “as agent
for BMAP”. According to petitioners:
An employee who is given cash by his employer
to purchase auto parts for his employer does not
receive income when he is given that cash. While
Mr. Vetrano could be adjudged stupid for cashing
checks made out to him in order to secure the
currency needed to buy auto parts for BMAP,
the evidence does not establish that these
disbursements were income to him. In fact, the
evidence establishes that these were non-income
disbursements made by BMAP to one of there [sic]
employees.
Second, petitioners assert that Mr. Vetrano simply
took the funds provided by BMAP and used them to purchase
the automobile parts supplied to BMAP. They assert: “It
is clear that Mr. Vetrano was a paid employee of BMAP and
purchasing parts for BMAP at a cost reflected as a purchase
expense on the books of BMAP.” As we understand it,
petitioners are asserting that the amount that Mr. Vetrano
paid for each of the automobile parts supplied to BMAP and
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