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Government. Under an agreement with ARL, Mr. Hall transported
Government freight across the United States as an independent
owner/operator.
ARL sent Mr. Hall weekly settlement statements. Each
statement consisted of a “permanent check voucher” and a
“settlement voucher,” which listed the income Mr. Hall had earned
on his trips for ARL, as well as any deductible charges he had
incurred during that week. The charges included rent due on the
trailer and other expenses advanced by ARL, such as truck tags
needed to cross into various States, taxes, and expenses with
respect to use of the leased trailer. Mr. Hall was obligated to
repay such expenses. Each item of income and expense was
enumerated. In the audit of their return by respondent,
petitioners provided roughly two-thirds of the weekly statements
for the year at issue. These statements were produced at trial.
Other statements were either misplaced or lost.
On the lower portion of each weekly settlement statement
were figures entitled, “YTD Amount” and “YTD 1099”. These
figures suggested a running total, as they tended to increase
with each later statement. However, some statements contained
the designation, “N/A,” in the “YTD Amount” or “YTD 1099" column.
The last statement for the year, dated December 21, 2000, showed
a “YTD Amount” of $54,197.69 and a “YTD 1099" of $43,983.72.
During the course of the year, Mr. Hall noticed that his
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Last modified: May 25, 2011