Duane A. Dworshak - Page 6

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          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:                                              












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