- 3 - The issues remaining for decision are: (1) Whether respondent proved that petitioners did not engage in their Amway activity for profit within the meaning of section 183; (2) if not, whether petitioners proved they are entitled to deduct expenses in carrying out the Amway activity as ordinary and necessary expenses under section 162; and (3) whether respondent proved that petitioners are liable for the accuracy-related penalties under section 6662(b)(1). The facts as stipulated are so found. The stipulation of facts and attached exhibits are incorporated herein by this reference. Petitioners resided in Austin, Texas, at the time they filed their petition. For convenience and clarity, we have combined the findings of fact and opinion. Petitioner Kenneth C. Theisen (petitioner) was employed full time by the Internal Revenue Service (Service) as a revenue agent during the years in issue. He had been so employed for the past 10 years. He has a Bachelor of Science in Accounting and is a Certified Public Accountant. During 1992 and 1993, petitioner Becky J. Theisen was employed as a travel agent. Petitioners were the parents of two children. Petitioners had been Amway distributors in 1979 and 1980. Petitioners again became Amway distributors in 1991, and were distributors during 1992 and 1993, the years in issue, and atPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011