Kenneth J. Nissley and Terri C. Connor Nissley - Page 8





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          At the time of trial (November 1999), petitioners anticipated               

          that for 1999, they would once again incur a loss from their                

          Amway activity.                                                             

               Petitioners determined their net losses from their Amway               

          activity on Schedule C of their tax returns for 1991 through                

          1998 as follows:                                                            



               1991       1992       1993       1994                                  
               Gross income1            $ 2,796    $11,387    $19,691    $ 5,609      
               Less: expenses                                                         
               (incl. home office)     13,054     39,113     39,396     33,016        
               Net loss                 $10,258    $27,726    $19,705    $27,407      

               1995       1996       1997       1998                                  
               Gross income1            $12,524    $17,129    $ 7,302    $ 7,584      
               Less: expenses                                                         
               (incl. home office)     46,063     44,916     29,527     26,691        
               Net loss                 $33,539    $27,787    $22,225    $19,107      


                         1For petitioners, gross income was essentially the           
                    bonuses earned from the sale (or personal consumption)            
                    of Amway products by “downline” distributors.                     
                    Petitioners themselves sold relatively few Amway                  
                    products, although they did order such products                   
                    on behalf of “downline” distributors.                             





















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