- 6 - channel and on any TPN products purchased by his customers from the TPN satellite channel or sales catalog. Petitioner focused his marketing activity on selling TPN and its products. He called and sent TPN cassettes, videotapes, and sales materials to potential customers of TPN products. In 1997, petitioner attended several conferences for TPN representatives in Dallas, Texas, where TPN was headquartered. The conferences featured direct marketing industry professionals and suppliers of TPN materials and products. Petitioner made lists of people he believed were potential customers of TPN products and who might be interested in becoming sales representatives. Petitioner met with these people and distributed sales materials to them. From June 1995 to December 1997, petitioner spent 10 to 20 hours per week on his marketing activity. D. Petitioner’s Tax Returns Petitioner reported gross income, expenses, and losses from his marketing activity on his 1995, 1996, and 1997 returns, and respondent conceded that petitioner substantiated business expenses for 1997, as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011