Ronald E. Byers - Page 7




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          Federal or State income tax withholding was ever shown on the               
          settlement reports that petitioner received from ECI.                       
               For each year in issue, ECI submitted to respondent and to             
          petitioner Forms 1099-MISC, Miscellaneous Income, reflecting for            
          each year petitioner’s cumulative gross earnings that ECI had               
          reflected on the settlement reports for each year and not                   
          reflecting earnings petitioner received for training truck                  
          drivers.                                                                    
               None of the earnings petitioner received from ECI were                 
          reported to respondent on a Form W-2, Wage and Tax Statement.               
               CCI did not submit to respondent or to petitioner Forms 1099           
          relating to petitioner’s compensation for oversight of CCI                  
          vehicles.                                                                   
               For the years in issue, petitioner’s annual gross earnings             
          from driving trucks as reflected on the Forms 1099 ECI submitted,           
          the amounts deducted by ECI and remitted to CCI for truck lease             
          payments, and the difference between the two are as follows:                

                Year Gross Earnings Truck Lease Payments Difference                   
                1999     $49,814            $25,900         $22,914                   
                2000     97,984             52,911          45,073                    
                2001      85,163             46,029          39,134                    
                2002     84,667             45,961          38,706                    










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