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Vickie L. Johnson, jointly owned 100 percent of the stock of
Service. Personal Elegance (Elegance) was 100 percent jointly
owned by the Johnsons, and Elegance, in turn, owned 100 percent
of Great. Each petitioner had its principal place of business in
Florida at the time of the filing of the petition. Mr. Johnson
had earned an associate's degree3 in tax and accounting.
Great provided educational services and seminars about
nutrition. Service provided business and computer services to
Great and to a related corporation. Service was on the accrual
method of accounting for Federal tax purposes and filed on a
calendar year basis. Great was also on the accrual method of
accounting for Federal tax purposes, yet filed on the basis of a
fiscal year ending (FYE) July 31.
Mr. Johnson had been associated with Glen Turner (Turner), who,
through seminars, promoted self-improvement. Turner also
promoted and franchised his operations during the 1960s and
1970s. After Turner had legal difficulties, Mr. Johnson
continued on his own in the same field, beginning around 1975.
Mr. Johnson established Elegance, a company that marketed
specialty gifts. That operation developed into the 1980
formation of Great, which held seminars on "self-improvement" and
marketed vitamins, nutritional products, health care products,
exercise programs, and the like.
3 We assume this was a 2-year, rather than a 4-year, college
degree.
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