Ralph E. and Mildred E. Galyen - Page 5

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          communicate with the subscriber by listing a number code to                 
          access the AdaCom computer.                                                 
               AdaCom also maintained a Web site directory of its program             
          subscribers.  AdaCom listed only program subscribers on the Web             
               In addition to receiving a listing in the AdaCom yellow                
          pages directory and on the Web site, the program entitled each              
          program subscriber to 5 hours of interpretative services of a               
          sign language interpreter.  Additionally, the program entitled              
          each program subscriber to 5 hours of audit defense, which                  
          consisted of representation before the Internal Revenue Service             
          (IRS) to defend the claiming of the section 44 credit and                   
          associated deductions of the program.  The audit defense services           
          did not cover representation at the IRS Appeals level or the cost           
          of litigation.                                                              
          The Subscription                                                            
               The subscription price of the program was $10,250 annually.            
          The program subscribers were entitled to pay $2,500 in cash and             
          provide $7,750 in promotional services to be performed by the               
          program subscribers.  The promotional service programs, which               
          AdaCom valued at $7,750, were as follows:  (1) Program A–11                 
          referrals by the program subscribers; (2) program B–7 referrals             
          by the program subscribers and the program subscribers were to              
          display and distribute AdaCom brochures; and (3) program C–4                

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Last modified: May 25, 2011