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with Renaissance in 2000 and 2001. His involvement in
Renaissance ended sometime in November 2001.
During his first year with Renaissance, petitioner drove his
personal automobile to St. Paul, Minnesota, twice a month for
training. By the second year, he traveled to Minnesota once a
month. As he began to recruit new members, petitioner had
meetings once every 2 weeks in his home.6 The meetings were held
in the basement of petitioners’ home which was furnished with a
conference table, a telephone, a computer, and a freestanding
chart board. The basement was not used by petitioners for
anything other than Renaissance meetings.
On Schedules C petitioners claimed deductions for business
expenses totaling $79,676 and $54,182 for 2000 and 2001,
respectively, for petitioner’s insurance business activity. No
Schedule C for either year was filed for expenses relating to the
Renaissance activities, rather the expenses for Renaissance were
commingled with the insurance business expenses. Both returns
were prepared by a tax return preparer referred to petitioners by
Renaissance.
6 Petitioner claims to have had approximately 33 of his
own Renaissance recruits.
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Last modified: May 25, 2011