Broadrick R. Moore and Dawn J. Ingram - Page 3




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          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
               Respondent determined deficiencies in petitioners’ Federal             
          income taxes of $2,138 in 1996 and $2,250 in 1997.  The issues              
          for decision are whether petitioners’ Amway activity was an                 
          activity engaged in for profit under section 183, and, if so,               
          whether petitioners have substantiated the claimed deductions               
          related to the activity.                                                    
          Background                                                                  
               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.                                      
               Petitioners were married during the tax years 1996 and 1997.           
          Their children, Chelsea and Kendall, were born in 1991 and 1995,            
          respectively.  Petitioner Broadrick Moore (hereinafter                      
          petitioner) worked full time as a lineman for an electric                   
          company, which required him to travel on occasion.  He was often            
          on call 24 hours a day, 7 days a week.  Petitioner Dawn Ingram              
          (hereinafter Ms. Ingram) worked full time as a receptionist in a            
          medical office during the years in issue.  Petitioners resided in           
          Beverly Hills, Florida, at the time that they filed their                   
          petition.                                                                   








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