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written agreement with Bennett Logging regarding the dispatch
services performed by petitioners.
For each of the years in issue, Bennett Logging issued Forms
1099 to Ruckman, Inc., for the amounts paid for hauling services.
With respect to the dispatch services performed by petitioners,
Bennett Logging issued Forms 1099 to Mrs. Ruckman personally
covering the amounts paid for such services in each of the years
in issue. The checks for dispatch services were made out to Mrs.
Ruckman personally and were deposited into petitioners' personal
bank account, rather than the corporate bank account.
Petitioners did not draw any salary or wages from Ruckman,
Inc., during the years in issue.
The amounts that Bennett Logging paid with respect to
dispatch services performed by petitioners totaled $43,009 and
$31,162 in 1989 and 1990, respectively. For 1989 and 1990,
Ruckman, Inc., reported the respective amounts on its Federal
income tax returns, Forms 1120S.
With respect to 1991, petitioners reported the amounts paid
by Bennett Logging with respect to dispatch services they
performed on Schedules C and SE of their joint return, Form 1040,
as Mrs. Ruckman's net earnings from self-employment as a
dispatcher. Also with respect to 1991, Happy Trucking, Inc.
(Happy Trucking), a corporation owned by Mr. Bennett and Mr.
Ruckman, issued a Form 1099 to Ruckman, Inc., for both dispatch
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Last modified: May 25, 2011