James R. and Janet M. Landrum - Page 4

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          14, 16, 21, and 24 years of age at the time of trial (January 22,           
               For convenience and clarity, additional findings of fact and           
          the applicable law are discussed together with respect to each              
          Background Concerning Amway                                                 
               Prior to the years in issue, petitioners had three separate            
          experiences with Amway, beginning in 1974.  Mr. Landrum was a               
          corporal in the Marine Corps and was stationed in Hawaii in 1974.           
          His Amway activity consisted of purchasing cases of wax from an             
          Amway distributor at wholesale, selling “a case or two a month to           
          [his] friends,” and keeping the difference between the wholesale            
          and retail prices.  He ceased his activities with Amway in 1976             
          when he was transferred from Hawaii and then released from active           
          duty with the Marine Corps.  After their marriage in 1977,                  
          petitioners participated in an Amway distributorship.  Their                
          experience with Amway was unprofitable, and they terminated it              
          after 2 years.  Petitioners became involved with Amway a third              
          time in 1985, while Mr. Landrum was employed at Goodyear.                   
          Although petitioners had about 50 persons reporting to them,                
          directly or indirectly, in the pyramid structure of Amway, there            
          were insufficient sales for profit.  Petitioners’ third Amway               
          venture lasted approximately 2 years, and again, petitioners                

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