FINDINGS OF FACT
Some of the facts and certain exhibits have been stipulated. The parties’ stipulations of fact are incorporated in this opinion by reference and are found accordingly. At the time he filed his petition, petitioner was a resident of New Jersey.
Petitioner is an independent contractor based in Cherry Hill, New Jersey. During the years in issue, petitioner lived in a house owned by his fiancé, Janis Pannepacker (Ms. Pannepacker) (we sometimes also refer to Ms. Pannepacker’s house as petitioner’s residence). During the years in issue, petitioner was building an addition to Ms. Pannepacker’s house in his spare time.
During the years in issue, petitioner worked with Raymond J. Mancino (Mr. Mancino) to renovate residential properties. During his 2005 tax year, petitioner worked on properties at the following locations: East Upsal Street, Philadelphia, Pennsylvania; Wissahickon Avenue, Philadelphia, Pennsylvania; and Seminole Avenue, Melrose Park, Pennsylvania. During his 2006 tax year, petitioner worked on properties at the following locations: Seminole Avenue, Melrose Park, Pennsylvania; Albright Avenue, Elkins Parks, Pennsylvania; and Coles Mills Road, Haddonfield, New Jersey. Those five work locations (hereinafter sometimes referred to as worksites) were 20.1, 15.7, 15.0, 14.7, and 4.0 miles, respectively, from petitioner’s residence. He worked at each of the worksites for a number of months and then, when the project at that worksite was finished, he moved to another worksite. Petitioner also received some income from his work as a track team coach.
Judge(s): Thomas Wells
Jurisdiction: U.S. Tax Court
Related Categories: Taxation
|Circuit Court Judge(s)|
|Petitioner Lawyer(s)||Petitioner Law Firm(s)|
|Glenn Bogue||Pro Se|
|Respondent Lawyer(s)||Respondent Law Firm(s)|
|Carrie Kleinjan||Internal Revenue Service|