Herbert Donald Singer - Page 6




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          programs.3  At trial, petitioner described several of these                 
          programs:                                                                   
                    And the first business I got into, in multi-level                 
               marketing, was marketing electricity.  I paid $1,250                   
               for the worldwide rights for the Los Angeles--well, the                
               United States rights.  And * * * it all went down the                  
               drain.  They could never deliver electricity.[4]                       
                              *   *   *   *   *   *   *                               
               I was in one that I’m still in, called Life Plus, which                
               has every disease known to mankind, and what particular                
               product in Life Plus to take for that.                                 
                              *   *   *   *   *   *   *                               
                    THE COURT: * * *  So we take it then that just                    
               about anything and everything under the sun is part of                 
               your ministry?                                                         
                    PETITIONER: No, no.                                               
                    THE COURT:  No?                                                   
                    PETITIONER: Only the things that I’ve actually                    
               joined, Your Honor.  And I gave you one of those, set                  
               up--                                                                   

               3  As we understand them, these multi-level marketing                  
          programs were essentially pyramid arrangements characterized by             
          various tiers and chains of “distributors”, each of whom was                
          interested less in the selling of “product” and more in the                 
          recruiting of “downline distributors”.  See, e.g., Nissley v.               
          Commissioner, T.C. Memo. 2000-178, for a description of the                 
          “pyramid” incentive system maintained by Amway Corp.                        
               4  Petitioner’s testimony occasioned the following colloquy:           
                    THE COURT:  You were going to be kind of like your                
               own Enron Corporation?                                                 
                    PETITIONER:  Well, something like that.  Anyone                   
               who came in, anyone in the United States was supposed                  
               to be under the people who originally got it started.                  
               Then they could never deliver electricity.                             





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