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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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