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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. 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. At the time the petition
was filed, petitioner resided in Benicia, California.
FINDINGS OF FACT
During the year in issue petitioner earned $24 hourly
working as a nurse and as a nursing consultant for Pleasant Care
Corporation (PCC). Petitioner began working for PCC during the
early 1990s. From that time through the year in issue petitioner
maintained an apartment in Stockton, California. During her
first few years of employment by PCC, petitioner regularly worked
in or near Stockton. From approximately March 31, 1996, until
2001, she was assigned to work at various facilities outside of
Stockton. In 1997, the year in issue, petitioner was assigned to
work at facilities in the following cities:
Round trip
Job site Number of weeks mileage from Stockton
Novato 9 171
Napa 1 141
Bakersfield 11 491
Ukiah 18 337
Yuba City 10 174
Petitioner was assured by her supervisor that the assignments
would only be temporary and that she would be reassigned to the
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