- 3 - 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 hisPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011