- 2 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011