Lang Her & Ka Moua - Page 3

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          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           
               Respondent determined deficiencies of $10,696 and $9,657 in            
          petitioners’ 2000 and 2001 Federal income taxes, respectively.              
          After concessions by the parties,2 the issue is whether                     
          petitioners are entitled to deduct certain business expenses on             
          Schedule C, Profit or Loss From Business, for an activity                   
          participated in by petitioner Lang Her (petitioner) for the years           
          in issue.  At the time the petition was filed petitioners resided           
          in Brown Deer, Wisconsin.                                                   
                                     Background                                       
               In 1995, Michael C. Cooper (Mr. Cooper) founded and                    
          incorporated a multilevel marketing company called Renaissance,             
          The Tax People, Inc.3 (Renaissance) in the State of Nevada, which           
          was operated out of Topeka, Kansas.  At its core, Renaissance was           
          a pyramid scheme.4  Its only product, the “Tax Advantage System”            

               2    In a stipulation of settled issues, respondent conceded           
          that petitioners are entitled to a Schedule C expense for                   
          supplies of $1,330 for the 2001 taxable year.  In a stipulation             
          of facts, petitioners conceded that they are not entitled to a              
          dependency exemption deduction for petitioner Lang Her’s father             
          for either the 2000 or 2001 taxable year.                                   
               3    Also known as RTTP; TheTaxPeople.net; Advantage                   
          International Marketing; AIM; and Renaissance Designer Gallery              
          Products, Inc.                                                              
               4    A pyramid scheme is an investment program designed such           
          that early investors are paid off with money paid into the                  
          program by later investors to encourage yet more and bigger                 
                                                             (continued...)           





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