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petitioners' view. At various times during either 1987 or 1988,
petitioners and Mr. Bennett discussed having petitioners perform
the dispatch services that were required in the operation of the
trucking business of Bennett Logging. Such dispatch services
consisted of procuring loads to be hauled, scheduling pickup and
delivery, assigning loads to particular trucks, verifying
delivery, answering drivers' questions about truck mechanical
problems, giving drivers instructions regarding proper loading of
unusual commodities, arranging for required licensing for transit
of trucks through various jurisdictions and similar
administrative matters, and billing. Dispatch services sometimes
entailed on-site visits to customers, but consisted primarily of
office work involving paperwork and telephoning.
Sometime between 1987 and 1989, petitioners began performing
dispatch services for Bennett Logging and continued to do so
during the years at issue. Mrs. Ruckman performed most, but not
all, of the dispatch services. Mr. Ruckman fielded drivers'
calls regarding mechanical problems and proper loading and made
the on-site visits to customers that were required. Mrs. Ruckman
generally did the remainder. The Ruckmans' two adult children
also occasionally assisted during the years in issue.
As required by then-applicable Interstate Commerce
Commission regulations, the contract between Ruckman, Inc., and
Bennett Logging for hauling services was written. There was no
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