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Petitioner maintained a joint checking account, account No.
68-205239, with Jan Weber (Ms. Weber) at First Hawaiian Bank,
from which Ms. Weber paid certain of petitioner’s bills. From at
least December 20, 1994, through around July 7, 1995, petitioner
also maintained a joint savings account, account No. 67-243539,
with Ms. Weber at First Hawaiian Bank.
Petitioner, who was a member of the International Union of
Operating Engineers Local 3 and Local 302, worked for Wilder
Construction Company (Wilder) in Alaska and for Goodfellow Bros.,
Inc. (Goodfellow), in Hawaii. Petitioner received $48,328.98 of
wage income from Wilder, from which Wilder withheld $119.50 of
Alaska State income tax. Petitioner received $10,862.56 of wage
income from Goodfellow, from which Goodfellow withheld $981.58 of
Hawaii State income tax. In addition to his wage income, peti-
tioner had $165 of taxable interest income.
Petitioner, who held a dive-master rating from the Profes-
sional Association of Dive Instructors (PADI), wanted to become
qualified to receive a dive-instructor rating from PADI. A
person who held a dive-master rating was qualified to assist a
dive instructor in teaching an individual how to dive. In no
event could a dive master certify an individual as qualified to
dive. Only a person who held a dive-instructor rating from PADI
was qualified to certify an individual as qualified to dive.
In order to become qualified as a PADI dive instructor,
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