- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011