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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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Last modified: May 25, 2011