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Petitioners’ legal residence at the time the petition was filed
was Vancouver, Washington.
Petitioner is an attorney who has a master of laws degree in
taxation and was previously employed as an auditor by the IRS
from 1987 to 1999. From January 1999 through April 15, 2002
(which includes the year at issue), petitioner was engaged in an
income-producing activity with Corben Financial Services (Corben)
of Lake Oswego, Oregon. The nature of petitioner’s income from
Corben and the nature of his activity is the principal issue in
this case. After termination of his affiliation with Corben in
April 2002, petitioner became a truck driver, driving what he
described at trial as “an 18-wheeler”.
Corben, from which petitioner earned income during the year
at issue, was in the trade or business of selling insurance,
primarily life insurance. Corben represented several life
insurance companies, and the employees and/or agents of Corben
were engaged in selling insurance that would meet the needs of
its customers. Corben, through its agents or employees,
conducted workshops, seminars, and marketing campaigns designed
to promote the sale of insurance. Petitioner was one of Corben’s
agents or employees and participated in these sale and marketing
activities.
For the year at issue, petitioners filed a joint Federal
income tax return, on which they reported no salary or wage
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