- 3 - Cafe”.2 The concept involved a retail food and drink establishment that served coffee and related items during the day, and wine and related items at night. Petitioner and his wife attempted to take a “two-pronged” approach to generating income from the Tasha’s Cafe concept. The first “prong” was to open a retail location in which petitioner and his wife could operate an actual wine and coffee bar. The second “prong” was to sell the concept to entrepreneurs as a franchise. Petitioner outfitted the basement of his home in the style of the proposed coffee and wine bar to determine the appearance and operation of Tasha’s Cafe and to model the concept for potential investors, local businesspeople, and franchisees. In his basement, petitioner installed restaurant-level food service equipment, coffee- and wine-related artwork, and two different types of flooring for testing purposes. Petitioner brought between 200 and 250 people to his basement model to promote the retail coffee and wine bar aspect of his business. Petitioner brought approximately 30 potential franchise customers to his basement to demonstrate the franchise possibilities of Tasha’s Cafe. While petitioner demonstrated the Tasha’s Cafe concept, he served coffee, wine, and food. Petitioner was never paid for the 2 For 2001, petitioner filed Form 1040, U.S. Individual Income Tax Return, with a filing status of single. For 2002, petitioner filed Form 1040, with a filing status of head of household.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007