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amounts reported by petitioners in connection with Marketing
Concepts Group.5
Petitioners filed a petition with this Court challenging the
disallowance of their Schedule C loss on the grounds that the
adjustments were “made incorrectly based on IRS assumption of a
startup business when in actuality it was a continuation of an
existing business.” At the subsequent trial, Mr. Weaver
testified and sought to explain petitioners’ business operations.
He also introduced a series of exhibits related to these
operations.6
For several decades, petitioners have been involved with
what can be broadly characterized as creative “marketing”
endeavors. The purpose of these operations has been and
continues to be the provision of advertising, marketing, and
business development services for third-party clients and for
original concepts developed internally. These efforts have
5 The precise nature of the relationship between the
Schedule C business, d/b/a Marketing Concepts Group, and the S
corporation Marketing Concepts Group, Inc., is not clear from the
record. The S corporation was apparently established to address
certain liability issues involved with major accounts and/or
public advertising campaigns.
6 At trial, respondent objected on similar grounds to two of
petitioners’ exhibits. On the second occasion, a discussion
ensued with respect thereto, and the objection was explicitly
overruled by the Court. In the interest of consistency and
because respondent’s objections are, as a practical matter,
mooted by our resolution of this case, we clarify that
respondent’s objection to Exhibit 12-P is also overruled for the
same reasons expressed in connection with Exhibit 15-P.
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Last modified: May 25, 2011