- 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
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