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FINDINGS OF FACT1
Petitioner resided in California at the time his petition
was filed. He timely filed his 1998 Federal income tax return,
Form 1040, U.S. Individual Income Tax Return, on which he
reported wage income of $54,640. During 1998, petitioner was
employed as an automobile salesman. From February 26 through the
middle of June 1998, petitioner worked at Concord Honda in
Concord, California (Concord). From the middle of June 1998
through October 12, 1998, petitioner worked at Honda of
Serramonte in Colma, California (Colma). Petitioner’s residence
at all pertinent times during 1998 was in Pleasant Hill,
California.
Petitioner had difficulty working with the general manager
at Concord, and he approached the personnel manager with his
problem. The personnel manager advised petitioner that the
Concord general manager would soon be leaving the Concord
location. The personnel manager offered to transfer petitioner
to the Colma dealership until the troublesome general manager
left Concord. The Concord dealership was only a few miles from
petitioner’s Pleasant Hill residence, whereas the Colma
dealership is approximately 64 miles from petitioner’s residence.
Petitioner made 97 round trips to the Colma location.
1 The parties’ stipulation of facts is incorporated by this
reference.
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