William F. Middleton - Page 3




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         (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.                                              





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