- 5 -
programs.3 At trial, petitioner described several of these
programs:
And the first business I got into, in multi-level
marketing, was marketing electricity. I paid $1,250
for the worldwide rights for the Los Angeles--well, the
United States rights. And * * * it all went down the
drain. They could never deliver electricity.[4]
* * * * * * *
I was in one that I’m still in, called Life Plus, which
has every disease known to mankind, and what particular
product in Life Plus to take for that.
* * * * * * *
THE COURT: * * * So we take it then that just
about anything and everything under the sun is part of
your ministry?
PETITIONER: No, no.
THE COURT: No?
PETITIONER: Only the things that I’ve actually
joined, Your Honor. And I gave you one of those, set
up--
3 As we understand them, these multi-level marketing
programs were essentially pyramid arrangements characterized by
various tiers and chains of “distributors”, each of whom was
interested less in the selling of “product” and more in the
recruiting of “downline distributors”. See, e.g., Nissley v.
Commissioner, T.C. Memo. 2000-178, for a description of the
“pyramid” incentive system maintained by Amway Corp.
4 Petitioner’s testimony occasioned the following colloquy:
THE COURT: You were going to be kind of like your
own Enron Corporation?
PETITIONER: Well, something like that. Anyone
who came in, anyone in the United States was supposed
to be under the people who originally got it started.
Then they could never deliver electricity.
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