- 3 - During the period (1965-1979) he worked for Goodyear, Mr. Hopkins, who participated in drag racing as a teenager, fre- quently attended automobile races. In 1980, Mr. Hopkins stopped frequenting such races. In 1985, he resumed attending automobile races, frequenting about 8 to 10 races a year. In at least 1999, the year at issue, Mr. Hopkins attended automobile races in different places throughout the United States, including Arizona, California, Indiana, Kentucky, Pennsylvania, and Texas. From 1982 until around mid-June 1999, Mr. Hopkins, operating as a sole proprietor under the name MPH Enterprises (Mr. Hopkins’s sole proprietorship), sold on behalf of certain manu- facturers, including Westchem, Inc. (Westchem), various plastics products and equipment used in the medical profession and the construction industry. In return for such services, Mr. Hopkins received sales-based commissions from such manufacturers. During approximately the first 5� months of 1999, Mr. Hopkins’s sole proprietorship sold on behalf of Westchem certain Westchem plastics products that resulted in (1) sales commissions to that sole proprietorship of an unspecified amount that was less than $128,6102 and (2) approximately $2.5 million of gross sales to 2As discussed below, petitioners reported that during 1999 Mr. Hopkins’s sole proprietorship had $128,610 of gross receipts (i.e., sales commissions). Westchem was not the only customer of Mr. Hopkins’s sole proprietorship, and the record does not disclose the amount of gross receipts (i.e., sales commissions) that Mr. Hopkins’s sole proprietorship received from its other (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011