Randall B. and Kay F. Ollett - Page 3

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               Respondent determined deficiencies in petitioners’ Federal             
          income taxes in the amount of $6,178 for 1999 and $7,940 for                
          2000.  The issue for decision is whether petitioners engaged in             
          their Amway/Quixtar activity during 1999 and 2000 with the                  
          objective of making a profit within the meaning of section 183.             
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  When they filed their               
          petition, petitioners resided in St. Charles, Illinois.                     
               Petitioners filed joint Federal income tax returns for 1999            
          and 2000.  At all relevant times, petitioner Randall Ollett                 
          (petitioner) was employed as a computer data security manager by            
          the American Medical Association in Chicago, Illinois.  He                  
          typically worked at this employment between 45 and 50 hours each            
          week and spent an additional 12 to 20 hours each week commuting             
          to and from work.  Petitioner Kay Ollett (Mrs. Ollett) worked               
          approximately 30 hours each week as a preschool teacher at                  
          Evangelical Covenant Church.  Petitioners reported combined wages           
          of $96,389 in 1999 and $98,949 in 2000.                                     
               Petitioner graduated from Princeton University with a                  
          bachelor of science degree in electrical engineering, and he has            
          a master’s degree in business administration from Lamar                     








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