Marie Key and David Glen Key - Page 2




                                        - 2 -                                         
               After concessions,1 the issues for decision are (1) whether            
          petitioners underreported their income for 1995 from their                  
          business reported on Schedule C, Profit or Loss From Business,              
          and (2) whether petitioners are liable for self-employment tax on           
          the net profit of the Schedule C business.                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, first supplemental stipulation of                 
          facts, and the attached exhibits are incorporated herein by this            
          reference.  At the time they filed their petition, Marie Key and            
          David Glen Key resided in California.                                       
          Multilevel Marketing Business                                               
               In early 1995, until approximately April 1995, Mr. Key sold            
          self-help motivational tapes for a multilevel marketing business            
          called Commonwealth.  After being terminated from Commonwealth in           
          April or May 1995, Mr. Key started his own multilevel marketing             
          business, modeled after Commonwealth, called The Winning Edge.              
          Mr. Key later changed the business’ name to The Ultimate                    
          Comeback.  Marie Key did administrative work for The Ultimate               
          Comeback.                                                                   
               The Ultimate Comeback marketed and sold a product called               
          “The Credit Maze Program” (the Credit Maze).  The Credit Maze was           


               1  Respondent concedes that petitioners are not liable for             
          $203,440 of the $545,715 of additional Schedule C business income           
          determined in the statutory notice of deficiency.                           




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011