Terry I. and Louise Major - Page 6

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          confirmed that his online resume and Web site were in existence             
          in 2001 and remained in existence as of the date of trial.                  
               Terry acknowledged that in 2001 he had provided computer               
          services for both Dollarhide and Lincoln, but, generally, he                
          denied that he had received compensation for his services.                  
          Respondent provided copies of checks issued by Dollarhide to                
          Major Computer Services and a copy of the Dollarhide general                
          ledger showing the same check amounts issued to Terry Major as              
          the vendor.  Julie Yows, director of operations for Dollarhide,             
          testified that in 2001 Dollarhide paid Terry for computer                   
          services rendered and issued him a Form 1099-MISC for 2001                  
          reflecting total compensation of $18,407.94.  Terry admitted that           
          when he received the notice of deficiency claiming he received a            
          Form 1099-MISC from Dollarhide, he did nothing to investigate               
          what he apparently contended was an error by Dollarhide.                    
               Louise was not present at trial.  Although respondent, in an           
          opening statement, referenced the deficiency and addition to tax            
          for Louise, Terry did not address any items respondent listed in            
          the notice of deficiency with respect to Louise.                            
               Respondent presented as evidence the declaration of Donna              
          Cooper, an employee in the tax department at Lincoln National               
          Corporation which together with its affiliates is known as                  
          Lincoln Financial Group.  Accompanying Ms. Cooper’s declaration             
          was a duplicate of the original Form 1099-MISC which Lincoln                

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Last modified: May 25, 2011