- 2 - All section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners are husband and wife and resided in Eldorado, Texas, at the time they filed their petition. Linda Gonzalez is a party to this proceeding only by reason of having filed a joint return with petitioner. Petitioner started to work for Wes-Tex Drilling Co. (Wes- Tex) in 1985. Petitioner worked only for Wes-Tex during 1992. During 1992, petitioner worked on different, remote wells as a chainman in a crew which worked on oil and gas drilling rigs. Wes-Tex provided all the tools which petitioner needed. Petitioner was required to pay for safety equipment and his transportation to and from the company's yard and worksite. Wes- Tex did not reimburse petitioner for these expenses. Wes-Tex paid petitioner an hourly wage that did not depend on the amount of oil or gas retrieved from the well. Wes-Tex issued petitioner a Form W-2 listing wages of $19,762.07 for 1992. Petitioner reported wages from Wes-Tex on Schedule C of his 1992 joint Federal income tax return (petitioner's return). Petitioner reported expenses of $6,220 on Schedule C, thereby reducing the claimed profit to $13,542.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011