- 15 - promotional income and that his gross income was understated by $53,179. The $69,915 amount is composed of three components. The first and second components are $5,452 of “8 cent coupon” income and $523 of postage income. Petitioner reported the $5,452 of “8 cent coupon” income as a portion of the total $16,736 of promotional income reported on his 1997 return. Petitioner conceded that he failed to report $523 in postage income. The remaining $63,940 (third component) was derived from the worksheets provided by petitioner. The rack and promotional income shown on all four worksheets totaled $63,940. Respondent points out that petitioner’s promotional contract with R.J. Reynolds was in effect during 1997, a fact that supports respondent’s determination. Petitioner argues that the worksheets are unreliable due to the fact that he was in the process of learning how to use a computer and made input errors. In addition, petitioner asserts that the R.J. Reynolds promotional contract was not in effect during 1997 and that he did not receive any payments under the contract. During 1997 petitioner received a check from R.J. Reynolds for $13,164, the quarterly amount called for in the promotional contract. Although the record does not reflect the specific purpose for the payment, it coincides with the amount called for in the promotional contract. Quarterly payments of $13,164 wouldPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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