Kenneth J. Nissley and Terri C. Connor Nissley - Page 7




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               As Amway distributors, petitioners were entitled to purchase           
          for their personal use Amway products at distributor’s cost                 
          without the customary 30-percent markup.  In 1994, 1995, and                
          1996, petitioners purchased Amway products valued at $2,133,                
          $3,282, and $3,786, respectively, for their personal use.                   
               Since inception, petitioners have treated their Amway                  
          activity as a proprietorship on Schedule C, Profit or Loss From             
          Business, of their Federal income tax return.  Petitioners                  
          describe their activity on Schedule C as “product distribution”             
          but do not identify the activity as an Amway distributorship.               
               Petitioners have never succeeded in earning a profit from              
          their Amway activity.  Rather, petitioners have consistently                
          claimed losses from their Amway activity and have used such                 
          losses to offset their other income, principally salary (or net             
          profit from business consulting) from their full-time positions.            
          The following schedule reflects the losses claimed by petitioners           
          from their Amway activity on Schedule C of their tax returns for            
          1991 through 1998:                                                          
                        Year                Net Loss                                 
                         1991 (part year)    $ 10,258                                 
                         1992                  27,726                                 
                         1993                  19,705                                 
                         1994                  27,407                                 
                         1995                  33,539                                 
                         1996                  27,787                                 
                         1997                  22,225                                 
                         1998                  19,107                                 
                         $187,754                                                     






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