Page:T.C. Memo. 2012-281.pdf/5

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domestically and internationally, for speaking engagements, and petitioner occasionally accompanied Mr. Hovind on these trips.

CSE also promoted its message through sales of merchandise that customers could purchase at the lectures or order through the mail. Most of CSE’s income derived from sales of merchandise, including clothing, videotapes, DVDs, CDs, bumper stickers, and mouse pads.[1] In addition to merchandise promoting the message of creation science, CSE sold books and videotapes promoting antigovernment and tax-protester arguments.[2] As CSE expanded its property holdings, CSE also generated income by renting its properties.

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  1. For example, in 2003 CSE earned gross receipts from merchandise sales of $1,657,329.
  2. For example, CSE sold “Good News for 1040 Filers”, a video by Joe Sweet, an individual who promoted the use of unincorporated business trust organizations to evade Federal income tax. The catalog description states that the video “[e]xplains how income tax is voluntary for most people”. Mr. Sweet has been permanently enjoined from “[o]rganizing, promoting, marketing, or selling the tax shelter, plan, or arrangement entitled ‘GOOD NEWS for FORM 1040 Filers: Your Compliance is Strictly VOLUNTARY! BAD NEWS for the IRS!’” and from “[o]rganizing, promoting, marketing, or selling ‘Unincorporated Business Trust Organizations’ (a/k/a ‘UBTOs’) or any other abusive tax shelter, plan, or arrangement that incites taxpayers to attempt to violate the internal revenue laws”. Petitioner wrote at least one check drawn on a CSE account to Mr. Sweet.