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The Court: Well, I’m willing to accept that you had a person
that broke a contract, but were all three years people
breaking contracts?
Ms. Jackson: No, Your Honor, 2001 was a sort of turning
point because I was trying to also introduce-–I mean, I was
doing this and also trying different things to generate
money. I tried. I mean, I was trying different things to
make this work. That’s why I was so ecstatic in 2002 when I
secured a contract.
The Court: Then the contract fell through.
Ms. Jackson: The contract fell through, but I am--
The Court: In 2003 you didn’t have any income from this
business.
Ms. Jackson: Well, in 2003 I was deciding that I’m going to
wrap this up, that, you know, I’m going to-–that’s why in
2004 I didn’t do any packing and shipping or limited to just
to see if I could sell the business, that I have enough
goodwill.
Petitioner claims that she prepared advertising and
promotional material for Packs to Go in the form of three
“infomercials” recorded on compact discs, digital video discs, and
videotapes. These materials (the cost of which petitioner claimed
as a business expense deduction) were prepared with the help of a
former brother-in-law over the course of a single weekend. In
addition, petitioner claims that her nephew created and maintained
a Web site for her Packs to Go activity. These materials were not
introduced into evidence; and there is no evidence, apart from
petitioner’s testimony that she conducted free seminars, of any
other strategy or tactic that petitioner used in an effort to
market her Packs to Go activity.
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Last modified: March 27, 2008