- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011