- 7 - 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.Page: 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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