Broadrick R. Moore and Dawn J. Ingram - Page 6




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          and “Tax Meeting”).  Petitioners also produced an “Office                   
          Expense” chart listing monthly totals for their office expenses             
          such as home mortgage, electricity, telephone, heat, property               
          taxes, termite treatment, child care, computer program, and                 
          C.P.A. fees for 1996.                                                       
               In 1997, petitioners had approximately 30 downline                     
          distributors in their distribution chain.  Petitioners realized             
          in 1996 that their activity was not as profitable as they had               
          hoped, and petitioners alleged that they changed their marketing            
          approach--that is, how they approached the activity and how they            
          contacted people.  They ended their Amway activity sometime in              
          the year 2000.                                                              
               Petitioners filed their 1996 and 1997 Federal income tax               
          returns as married filing jointly.  They reported gross income              
          from wages in the amount of $66,966 in 1996 and $68,399 in 1997.            
          Petitioners reported income and claimed expenses on Schedules C,            
          Profit or Loss From Business, with respect to their Amway                   
          activity as follows:                                                        

















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