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for employment taxes for elected tribal officials. In return for
this information, Mr. Doxtator sought a "finder's fee" equal to 6
percent of the taxes recovered pursuant to the ruling. He
contacted tribes seeking meetings to present his advice and
requested that the tribes provide him with meals and lodging in
connection with his travel to the meetings. Mr. Doxtator
traveled as far as 500 miles for such meetings and made repeat
visits in some instances.
During the years at issue, Mr. Doxtator never received
payment of any finder's fees. He considered there to be oral
agreements regarding his fees with the tribes with whom he met.
After failing to receive payment, he did not seek written
contracts; instead, he sought to recover the fees by requesting
payment from newly elected members of the tribal leadership.
On the 1997 Schedule C for Native American Finance,
petitioners reported gross receipts of $613, cost of goods sold
of $225, and expenses of $7,580. On the 2000 Schedule C for
Native American Finance, petitioners reported gross receipts of
$465 and expenses of $7,748. The amount reported as gross
receipts comprised reimbursements of travel expenses to Mr.
Doxtator by the tribes he visited. Some of the expenses claimed
on the 1997 and 2000 Schedules C were Mrs. Doxtator's travel
expenses incurred in connection with her duties as a judicial
officer.
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