Desta Taye-Channell and Bruce C. Channell - Page 6

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          were to display and distribute AdaCom brochures and display an              
          AdaCom window decal.                                                        
               AdaCom advised program subscribers to include $7,750 in                
          income, deduct $5,250 as an ordinary and necessary business                 
          expense pursuant to section 162, and claim a credit equal to                
          $5,000 pursuant to sections 38 and 44.  The deduction of $5,250             
          comprised the $2,500 cash paid plus the excess of the promotional           
          services income over the claimed credit amount--$7,750 minus                
          $5,000, which equals $2,750.  AdaCom issued a Form 1099-MISC,               
          Miscellaneous Income, in the amount of $7,750 to each program               
          subscriber.                                                                 
               None of the people referred by the program subscribers were            
          required to subscribe to the program in order for the referring             
          program subscriber to obtain credit towards the purchase price of           
          the program.                                                                
          Petitioners’ Tax Return                                                     
               During the 2000 tax year, petitioner Bruce Channell was                
          employed as a financial analyst, and petitioner Desta Taye-                 
          Channell was employed as a job coordinator.  For 2000,                      
          petitioners filed a Schedule C, Profit or Loss From Business,               
          claiming a business of “Membership Sales and Prepaid Legal                  
          Services”.                                                                  
               On December 30, 2000, petitioners subscribed to the program.           
          Petitioners chose promotional service program C and furnished               






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Last modified: May 25, 2011