Broadrick R. Moore and Dawn J. Ingram - Page 5




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          they used to prepare monthly and long-term expense and income               
          reports used for budgeting.  With the exception of the advice               
          from their C.P.A., petitioners did not seek guidance from an                
          independent source.                                                         
               Petitioners prepared a handwritten outline of their                    
          statement of goals in their January 1995 calendar notes.                    
          Petitioners’ goals included recruiting three downline                       
          distributors every month who would, in turn, find three of their            
          own downline distributors.  The goals also project and calculate            
          commissions to be received from the downline distributors and               
          customers.  For example, the goals included as follows: “Increase           
          300PV Per Month” and “Find 10 Customers = 500 - 1000 PV”.                   
               Petitioners maintained calendars for 1996 and 1997 with                
          their daily personal and Amway engagements.  These calendars have           
          handwritten entries indicating cities, hotels, and other items              
          such as “STP” (show the plan--a marketing of their business                 
          plan), but it is not always clear which entries are related to              
          the Amway activity.  Petitioners maintained daily and monthly               
          logs of “Business Expenses”, charts of their miles traveled,                
          parking, tolls, fares, meals, lodging, and other expenses (e.g.,            
          tickets) from January 1996 through December 1997.  In the                   
          “Business Purpose - Where, Why, Who, etc.” column in these                  
          charts, petitioners wrote various cities, words, and                        
          abbreviations (e.g., “Ft. Lauderdale STP”, “Gainsville Seminar”,            






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