Karl Meyer and Vickie Meyer - Page 11




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               F.  Petitioners’ Reconciliation and the Termination of the             
          Amway Activity                                                              
               By November 1997, petitioners had reconciled, and the                  
          divorce action was nonsuited.  Subsequently, at some point in               
          1998, petitioners decided that they would no longer actively                
          pursue the Amway activity.  Since that time, however, Mrs. Meyer            
          has continued to renew her status as an Amway distributor in                
          order to retain the right to purchase Amway products, such as               
          vitamins and cleaning products, for petitioners’ personal use at            
          discount prices.                                                            
               G.  Petitioners’ Schedule C Losses                                     
               For all relevant years, specifically including the taxable             
          years 1994 through 1998, petitioners filed joint Federal income             
          tax returns.  Petitioners attached to each of those returns a               
          Schedule C, Income or Loss From Business, identifying “Karl L.              
          Meyer” as “proprietor” of “Meyer Enterprises” and describing the            
          principal business or service of such enterprise as                         
          “Distribution”.                                                             
               Petitioners have never reported a profit from the Amway                
          activity.  Rather, petitioners have consistently claimed losses             
          from this activity and have used such losses to offset Mr.                  
          Meyer’s compensation as a salesman.                                         
               The following schedule reflects the losses claimed by                  
          petitioners from the Amway activity on Schedules C of their tax             
          returns for 1994 through 1998:                                              





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