Jorge N. and Vivian Lopez, (2003)

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Jorge N. and Vivian Lopez, (2003)

T.C. Memo. 2003-142

UNITED STATES TAX COURT JORGE N. LOPEZ AND VIVIAN LOPEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8612-01. Filed May 20, 2003.

Jorge N. Lopez and Vivian Lopez, pro sese. David B. Mora, for respondent.

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: Respondent determined deficiencies of $3,833 and $3,810 in petitioners' Federal income taxes for the years 1998 and 1999, respectively. The issue for decision for each year is whether petitioners are entitled to deductions for expenses incurred in connection with the sale and distribution of Amway Corp. (Amway) products. The resolution of this issue for each year depends upon whether petitioners' Amway distributorship was a trade or business within the meaning of section 162.1 Background Some of the facts have been stipulated and are so found. Petitioners are husband and wife. They filed ...

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