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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in London, England, when they filed
their petition. From July through December 1987, petitioner
performed services as an independent contractor for Con Tex, Inc.
The stubs detached from the checks for services which petitioner
received from Con Tex, Inc., reveal that of the total amount
petitioner received from July 13, 1987, to December 16, 1987,
$18,485 represented reimbursed expenses. In addition, of the
$2,784 petitioner received on December 30, 1987, $384 represented
reimbursed expenses. Thus, petitioner's expense reimbursement
from Con Tex, Inc., totaled $18,869.
OPINION
In an opening statement preceding his testimony, petitioner
represented to the Court that he was engaged by Con Tex, Inc., as
a "contract worker" in connection with a contract that Con Tex,
Inc., had with Ford Motor Company (Ford) to introduce certain
systems and procedures to Ford. Petitioner stated that Con Tex,
Inc., was terminated by Ford after 7 months, and that both he and
Con Tex, Inc., ended up losing money.
Petitioner testified that, insofar as his services as a
contract worker were concerned, Con Tex, Inc., agreed to
reimburse him for air fares and accommodations that he "would
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