Emmanuel & Cecilia Abloso - Page 6

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               During 2000, petitioner “sponsored” approximately 29                   
          individuals, predominantly friends and relatives, as TRS                    
          participants.  For his referrals, petitioner earned “bonuses”               
          from Renaissance which totaled $2,914 during 2000.                          
               For the most part, petitioner conducted his TRS activities             
          in the dining room of petitioners’ residence.  Petitioner did not           
          maintain any separate books or records with regard to the TRS               
          activity other than mileage logs and petitioners’ monthly bank              
          statements.  Cecilia Abloso, who was employed as nurse during               
          2000, did not participate in the TRS program.                               
               Petitioner terminated his involvement with the TRS program             
          at the end of 2000 when he discovered that Renaissance was                  
          involved in a dispute with the Internal Revenue Service.                    
               Petitioners filed a timely joint 2000 Federal income tax               
          return.  An accountant at ANVICOM is listed as the paid preparer            
          of that return.  Included with that return is a Schedule C                  
          related to petitioner’s participation in TRS.  The Schedule C               
          shows a net loss of $14,205.  The loss takes into account the               
          following expense deductions:                                               
                         Advertising              $896                                
                         Car and truck expenses   3,189                               
                         Office expense                120                            
                         Rent or lease                                                
                         Vehicles and equipment     6,480                             
                         Supplies                      413                            
                         Meals and entertainment       114                            
                         Utilities                     180                            
                         Other expense              5,727                             
                         Total               17,119                                   





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