Harvey L. Hoover - Page 7

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          The above-stated expenses consisted of hauling, market orders,              
          NDPRB, CCC, and Cream LIC expenses.6                                        
               Petitioner also sold cattle as part of his farming business.           
          During the years in issue, Jon Hayes or his father Porter Hayes             
          (the Hayeses) purchased male calves from petitioner.  The Hayeses           
          typically paid petitioner $100 to $125 per calf.  When Jon Hayes            
          purchased cattle from petitioner, he always left the payee’s name           
          blank.  The checks with which the Hayeses purchased the cattle              
          were ultimately made payable to petitioner or Michael Hoover in             
          amounts totaling $3,455 in 1990, $1,375 in 1991, and $375 in                
          1992.7  The checks from the Hayeses were as follows:                        
          Year Issued           Check No.        Payee         Amount                 
               1990                112       Harvey Hoover      $770                  
               1990                --        Harvey Hoover       550                  
               1990                106       Harvey Hoover       900                  
               1990                109       Harvey Hoover       770                  
               1990                116       Harvey Hoover       250                  
               1990                121       Harvey Hoover       275                  
               1991                226       Harvey Hoover       500                  
               1991                232       Harvey Hoover       375                  
               1991           2448           Mike Hoover         250                  
               1991           2473           Michael Hoover      125                  


               6 The parties did not explain the expenses listed as NDPRB,            
          CCC, and Cream LIC.                                                         
               7 Respondent asserts that petitioner received income in 1992           
          of $1,875 from the sale of calves to the Hayeses.  The record               
          contains only one canceled check from 1992; the Hayeses issued a            
          $375 check to petitioner in 1992.  Respondent relies on a summary           
          exhibit prepared and used by a revenue agent in the criminal                
          prosecution of petitioner to argue that petitioner received                 
          $1,875 from the Hayeses in 1992.  We find that petitioner                   
          received $375 from the Hayeses in 1992.                                     




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