Robert A. Eder - Page 3




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          other court, and this opinion shall not be treated as precedent             
          for any other case.                                                         
               Respondent determined a $3,172 deficiency in petitioner’s              
          2002 Federal income tax.  The issue for decision is whether                 
          during 2002 petitioner engaged in his Reliv International                   
          marketing activity for profit within the meaning of section 183.            
                                     Background                                       
               The parties have stipulated many facts, which are so found.            
          When he petitioned the Court, petitioner resided in Indiana.                
               Petitioner is single, having divorced in 1994.  He holds a             
          master’s degree in civil engineering.  In 1991, he began working            
          as an engineer at Abbott Laboratories (Abbott).  During 2002, he            
          worked for Abbott 9 hours a day, 5 days a week, receiving wages             
          of $85,064.84.                                                              
               In 1997, while employed at Abbott, petitioner met a couple             
          at his gymnasium.  They convinced him to become an independent              
          distributor for Reliv International (Reliv), a network marketing            
          company that sells health care products.  Petitioner had no                 
          previous experience in network marketing or retail sales.                   
               According to petitioner, he can make a profit on sales of              
          Reliv products, which he orders directly from Reliv.  He regards            
          any profits from direct sales, however, as incidental to the                
          supposedly more lucrative goal of “sponsoring” other people in              








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