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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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