David M. Sears and Carol L. McCabe - Page 4

                                        - 3 -                                         
               In 1999, petitioners became associated with Renaissance, The           
          Tax People, Inc. (RTP), also known as Advantage International               
          Marketing.  RTP sold a product called “The Tax Relief System”               
          (the system), which was designed to generate Federal income tax             
          deductions.  RTP claimed that by establishing a “home-based                 
          business” activity, a taxpayer could convert personal expenses              
          into business expenses.  The system consisted of various written            
          materials that RTP sold for $400.  RTP promised to refund the               
          purchase price if a taxpayer failed to generate at least $5,000             
          of Federal income tax deductions during the first 12 months of              
          using the system.                                                           
               RTP also sold a related service called “Platinum Tax                   
          Advantage” (the platinum service)3 that was available to                    
          customers who purchased the system.  For $100 a month, platinum             
          service members could contact RTP and receive tax and financial             
          planning advice.  RTP also claimed it would prepare customers’              
          tax returns and represent them before the Internal Revenue                  
          Service (IRS) in the case of an audit.                                      
              RTP sold the system and the platinum service by means of                
         “multi-level marketing” or “network marketing”.  A “downline”                
         distributor was recruited by an “upline” distributor.  An upline             
         distributor earned a $30 commission for every sale he made of the            
         system and an additional $3 commission for each month a downline             

               3  The parties also referred to the platinum service as                
          “Prepaid Tax Advantage.”                                                    




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