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indicated, subsequent section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners’ Federal
income taxes of $2,138 in 1996 and $2,250 in 1997. The issues
for decision are whether petitioners’ Amway activity was an
activity engaged in for profit under section 183, and, if so,
whether petitioners have substantiated the claimed deductions
related to the activity.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Petitioners were married during the tax years 1996 and 1997.
Their children, Chelsea and Kendall, were born in 1991 and 1995,
respectively. Petitioner Broadrick Moore (hereinafter
petitioner) worked full time as a lineman for an electric
company, which required him to travel on occasion. He was often
on call 24 hours a day, 7 days a week. Petitioner Dawn Ingram
(hereinafter Ms. Ingram) worked full time as a receptionist in a
medical office during the years in issue. Petitioners resided in
Beverly Hills, Florida, at the time that they filed their
petition.
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