Michael A. Ogden - Page 9




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          activities an average of 25 hours per week, while Mrs. Ogden                
          alleged she worked between 10-15 hours per week.  It is difficult           
          to believe Mr. Ogden worked 25 hours per week while he traveled             
          to and maintained a full-time job with significant and expanding            
          responsibilities.  We are not required to accept the self-serving           
          testimony of either petitioner as gospel.  Tokarski v.                      
          Commissioner, 87 T.C. 74, 77 (1986).                                        
               Mrs. Ogden claimed she spent 2 hours one day a week waiting            
          for telephone orders on what she characterized as a weekly call-            
          in sheet.  The weekly call-in sheet for her five personal                   
          downliners is revealing in that it listed only 50 miscellaneous             
          household products.  Most of the items on the list were for one             
          item.  A sample of these items are: One crisp rice, 13 ounces;              
          one marinara pasta sauce, 25 ounces; one meatless ravioli, 9                
          ounces; one trash bags, 13 gallons; and one bar soap, 3.25                  
          ounces.  According to Mrs. Ogden's testimony, several days after            
          she prepared the call-in sheet, she drove to her upline                     
          distributor to pick up those products at 11:00 p.m. and did not             
          get home until 2 or 3 a.m.  Mrs. Ogden claimed that it could                
          "take anywhere from an hour to an hour-and-a-half just to check-            
          off all the products and make sure everything is there and put it           
          in -pack it in your car- and then drive home, another 45                    
          minutes."  The following day, downliners came to her house from             
          6:30 a.m. to 8:30 a.m. to pick up their products.  Her testimony            
          lacks credibility.                                                          




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