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statements had inaccuracies. Specifically, he did not understand
the instances when “N/A” appeared in the “YTD Amount” or “YTD
1099" column. Both he and Mrs. Hall attempted to contact ARL on
several occasions for explanations; however, they were
unsuccessful. Mr. Hall described these efforts to the Court:
During the course of the year, I had the pleasure to
call ARL constantly and question them about the figures on
the bottom of the settlement. The woman said okay, we’ll
try to get it straight. We’ll straighten it out.
* * * * * * *
I couldn’t make heads or tails just looking at their
paperwork that they * * * [were] giving me a true figure
because I had inquired to these people over and over that my
statements didn’t look right. The figures wouldn’t match.
I was asking them for help to figure out their own
paperwork, and the woman there told me that she would try to
figure it out. Don’t worry about it. It will be corrected.
Just keep on trucking. I was being honest with them, and I
was hoping that they were being honest with me.
* * * * * * *
When the figures did show up, I thought it was
corrected. I took it at face value that the figures were
correct.
Petitioners eventually lost faith in ARL. Mr. Hall left the
company in December 2000 to pursue more local trucking work with
a different company.
Petitioners filed their 2000 Federal income tax return
timely. On Schedule C, they reported $47,773 in gross receipts
or sales from Mr. Hall’s activity as a truck driver. This amount
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