William C. and Dorothy M. Smith - Page 9




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               The time Mrs. Smith did spend with these direct marketing              
          activities was devoted primarily to recruiting additional                   
          downline distributors as opposed to selling the actual products             
          themselves.  To recruit additional distributors, Mrs. Smith                 
          placed advertisements in the classified sections of local and               
          regional newspapers about joining her marketing organization.               
          For instance, one advertisement under the heading, “Network                 
          Marketers” states:  “The top trainer in the industry seeks 5 key            
          people in the Nashville area. $25,000/mo. FREE car.”  Mrs. Smith            
          would then spend time responding to phone calls inquiring about             
          these advertisements as well as traveling to and meeting with               
          these potential downline distributors.  Mrs. Smith would also               
          prepare periodic goal sheets, with stated numbers of the sales              
          she hoped to make, and review similar goal sheets prepared by her           
          downline distributors.  Finally, Mrs. Smith would meet with other           
          distributors during conferences and seminars.                               
               It is not clear how many downline distributors resulted from           
          these recruitment efforts by Mrs. Smith.  Many of her downline              
          distributors did, however, come from among Mrs. Smith’s family              
          and friends.  For instance, one of the first members of Mrs.                
          Smith’s Renaissance team was her husband, Dr. Smith.3  Another              


               3Mrs. Smith offered no explanation of what benefit                     
          petitioners might have received from Dr. Smith’s purchasing the             
          Tax Relief System when Mrs. Smith had already purchased the                 
          system and the platinum level of service.                                   






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Last modified: November 10, 2007