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...
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