Herbert Donald Singer - Page 7




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                    THE COURT:  I mean, let’s put it this way,                        
               anything you get involved in, becomes part of your                     
               ministry.  Is that what you're telling us?                             
                    PETITIONER:  Well, if I sign up for a multi-level                 
               marketing situation, then that’s part of what I am                     
               using in the overall picture to help people to make                    
               money.                                                                 
               C.  Recordkeeping                                                      
               Petitioner did not maintain a separate bank account for his            
          “health, wealth and healing ministry” activity.  Rather, he                 
          maintained a single checking account for all of his affairs.                
               Of the hundreds of checks that he wrote during the years in            
          issue, petitioner categorized the vast majority, including all of           
          the checks written to grocery stores, as “unreimbursed employee             
          expenses”.  Indeed, petitioner categorized only a couple of                 
          checks (in the aggregate amount of $40) as “household expenses”.            
          In this regard, petitioner testified at trial that he lived with            
          his mother who paid most, if not all, of his personal living                
          expenses.  Thus, for example, petitioner testified: “I                      
          wasn’t buying any of the food.  My mother was buying it all.”               
          and that “I didn’t do any of my own shopping.”                              
               D.  Financial Track Record of Petitioner’s Activity                    
               As of the date of trial, petitioner had yet to make a profit           
          in his “health, wealth and healing ministry” activity.                      
               E.  Petitioner’s 1996 Income Tax Return                                
               Petitioner filed a Format U.S. Individual Income Tax Return,           
          Form 1040PC, for 1996, listing his occupation as “healing                   





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