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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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