Paul R. Peete - Page 7

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          activity.  Petitioner’s business activities consisted of meeting            
          with people and trying to recruit them into the activity.                   
          Petitioner testified that his tax return preparer, Robin Manasseh           
          (Ms. Manasseh), introduced him to the scheme and told him that he           
          could deduct expenses related to recruiting other individuals.              
          After getting involved, petitioner testified that he discovered             
          that Ms. Manasseh was being investigated and that she informed              
          petitioner to stop trying to recruit people until the                       
          investigation was finished.                                                 
               Petitioner had difficulty explaining how the various items             
          constituting the Schedule C loss related to a business activity.            
          He testified that he did not know of any advertising expenses,              
          that he had “absolutely no idea” what the $24,944 reported as               
          depreciation related to, that he did not know what the $8,707 in            
          repair service expenses related to, and that he did not make any            
          gifts to charities other than those listed on other parts of his            
          tax return.  He testified that he claimed expenses related to               
          playing golf and meals on the basis of the advice of Ms.                    
          Manasseh.  Petitioner acknowledged that it occurred to him that             
          this may have been too good to be true and that he did not take             
          steps to investigate what he was told other than trusting the               
          judgment of Ms. Manasseh.  Petitioner also acknowledged a large             
          part of food expenses were for meals that he had by himself and             








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