Joe Guadagno and Susan Beth Rishel Guadagno - Page 3

                                        - 2 -                                         
               Respondent determined deficiencies in petitioners’ Federal             
          income taxes of $3,976, $3,790, and $5,420 for 1996, 1997, and              
          1998, respectively.  The issue for decision for each year is                
          whether petitioners are entitled to deductions for expenses                 
          incurred in connection with the sale and distribution of Amway              
          Corp. (Amway) products.  The resolution of this issue for each              
          year depends upon whether petitioners’ Amway distributorship was            
          a trade or business within the meaning of section 162.                      
               Some of the facts have been stipulated and are so found.               
          Petitioners are husband and wife.  They filed a timely joint                
          Federal income tax return for each year in issue.  At the time              
          the petition was filed, petitioners resided in Fredericksburg,              
               At all relevant times Joe Guadagno was an officer in                   
          the U.S. Marine Corps.  Through June 1996, and then again                   
          from December 1996 through February 1997, Susan Guadagno was                
          employed full time as a systems analyst by Systems Maintenance &            
          Technology, Inc.                                                            
               Toward the end of 1995, while living in North Carolina,                
          petitioners were contacted by a distributor of Amway products;              
          soon thereafter they became users and distributors of Amway                 
          products.  Petitioners moved to Virginia in 1998.  They continued           
          to use and distribute Amway products throughout the years in                

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011