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assigned geographical territory in Texas for the purpose of
demonstrating and selling Xomed’s products.
Mr. Meyer is compensated by Xomed on a straight commission
basis, and he is precluded by his employer from participating in
other for-profit sales activities. His compensation for 1994
through 1999 was $80,114, $83,403, $116,186, $97,329, $140,008,
and $149,610, respectively.
B. Petitioner Wife
Petitioner wife (Mrs. Meyer) is a homemaker and mother of
three children: Alexandra, born in July 1989; Jeffrey, born in
August 1993; and Andrea, born in March 1995.
In 1985, Mrs. Meyer filed an assumed name certificate with
the Harris County (Houston, Texas) Clerk’s Office, adopting the
business name of Vickie Zozaya Enterprises. However, Mrs. Meyer
never conducted any type of activity with respect to this
enterprise.
In 1994, Mrs. Meyer began designing and making jewelry pins
and selling them at craft shows under the assumed name of
Trinkets, Etc. Less than a year thereafter, Mrs. Meyer ceased to
operate Trinkets, Etc. because its time-consuming nature and lack
of profitability did not allow Mrs. Meyer to properly care for
her children. Petitioners’ income tax return for 1994 included a
Schedule C, Profit or Loss from Business, claiming a net loss of
$188 (i.e, gross income of $247 less car expenses of $435) from
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