- 3 -
(5) whether petitioner is liable for additions to tax under
section 6651(a)(1) for 1991.
FINDINGS OF FACT2
Petitioner resided in Charles Town, West Virginia, when his
petition was filed with this Court. During the taxable years
under consideration, petitioner owned and operated a taxi cab
business in Montgomery County, Maryland (the county). Pursuant
to oral agreements, petitioner leased taxi cabs (taxis) to
independent drivers for a daily fee in a range of $55.00 to
$97.00. The driver/lessees paid their own operating expenses,
including gasoline. Petitioner maintained a daily record of the
lease of taxis, and the drivers were required to settle their
accounts on a weekly basis. During 1989 and 1990, petitioner
received $8,812 and $129,136, respectively, from the drivers for
the lease of taxis.
Petitioner also contracted with the county to provide
Medicaid recipients with taxi service to and from approved
locations, such as doctors’ offices and rehabilitation centers.
Under the agreement, the county would fully reimburse petitioner
for amounts specified on his invoices. In addition to the
reimbursements, the county agreed to pay petitioner 8 percent of
2 The parties’ stipulation of facts and exhibits is
incorporated by this reference.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011