Kenneth J. Nissley and Terri C. Connor Nissley - Page 2

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               The issue for decision by the Court is whether petitioners             
          engaged in their Amway activity for profit within the meaning of            
          section 183.1  We hold that they did not.                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners resided in Indianapolis, Indiana, at the time           
          that their petition was filed in this case.                                 
               Petitioner husband (Mr. Nissley) graduated in 1982 with a              
          bachelor of science degree in accounting from Manchester College            
          in North Manchester, Indiana.  He was licensed as a certified               
          public accountant (C.P.A.) in 1982.  Thereafter, from 1982                  
          through 1987 he worked as a staff auditor, a senior auditor, and            
          ultimately as an audit manager for the Big 5 accounting firm of             
          Price Waterhouse.                                                           
               Since January 1988, Mr. Nissley has been employed on a full-           
          time basis (40-50 hours per week) as the director of information            
          systems and planning and procurement for Creative Expressions               
          Group, Inc. of Indianapolis, Indiana.  His salary for 1994, 1995,           
          and 1996 was $65,674, $67,916, and $70,810, respectively.                   

          1  All section references are to the Internal Revenue Code,                 
          in effect for the taxable years in issue, and all Rule references           
          are to the Tax Court Rules of Practice and Procedure.  All                  
          amounts are rounded to the nearest dollar.                                  

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