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Employer 1992 1993 1994 1995
Linde $57,840 $58,167 $60,585 –-
Hartmann –- –- 4,469 $14,606
Motiontek –- –- –- 10,400
Worksmart -- –- –- 35,476
For taxable years 1992, 1993, and 1994, Linde withheld Federal
income taxes of $7,701, $7,813, and $5,925, respectively, from
petitioner's wages. Additionally, for taxable year 1994,
Hartmann withheld Federal income tax of $857, and for taxable
year 1995, Hartmann, Motiontek, and Worksmart withheld Federal
income tax of $2,845, $900, and $5,592, respectively.
In addition to his full-time employment, petitioner
performed services as an engineering consultant. Petitioner's
consulting business involved working principally for two
companies: Tri-State Hydraulics, Inc. (Tri-State), and American
Fluid Power, Inc. (American). To perform his business services,
petitioner would travel by automobile from his home to
approximately nine client sites in Wisconsin and Illinois.
Petitioner earned nonemployee compensation from his consulting
services as follows:
Employer 1992 1993 1994
Tri-State $6,600 $12,626 $7,000
American 263 1,767 1,212
Petitioner operated his consulting business out of a garage
attached to his residence. The garage contained a desk, a
drafting table, two phones, and filing cabinets. The garage made
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