Uber Gonzalez and Linda Gonzalez - Page 2

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               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.                 




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