- 6 - payment method. Petitioner directed Best Ever Dairy to issue one check payable to petitioner in the amount of $10 and a second check payable to Tadd Hoover in an amount equal to the balance due. Petitioner also instructed Best Ever Dairy to mail both checks to petitioner. From August 30, 1990, through December 31, 1992, Best Ever Dairy followed petitioner’s instructions. The milk proceeds belonged to petitioner. When Tadd Hoover received checks from Best Ever Dairy, he endorsed the checks and gave them to petitioner. Sometime after petitioner told Best Ever Dairy to split the milk sales checks between Harvey Hoover and Michael Hoover or Tadd Hoover, petitioner advised Michael that he was reporting all of the milk sales on his tax returns and paying the taxes due on the milk sales. Petitioner’s milk sales to Best Ever Dairy were computed by Best Ever Dairy in terms of gross sales from which it deducted certain expenses attributable to petitioner and remitted the net amount to petitioner. Petitioner received milk sale proceeds from Best Ever Dairy as follows: Year Gross Sales Expenses Net Sales 1990 $146,416.57 $8,615.19 $137,801.38 1991 101,047.40 7,278.94 93,768.46 1992 117,274.22 8,456.73 108,817.49Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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