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is indicative of a lack of profit objective. This factor favors
respondent.
9. Elements of Personal Pleasure or Recreation
Personal or recreational aspects of an activity may indicate
that the activity was not conducted with a profit objective.
McKeever v. Commissioner, T.C. Memo. 2000-288; sec. 1.183-
2(b)(9), Income Tax Regs. The mere fact that a taxpayer derives
pleasure from an activity, however, does not show a lack of a
profit objective if the activity is, in fact, conducted for
profit as evidenced by other factors. Sec. 1.183-2(b)(9), Income
Tax Regs.; see also Jackson v. Commissioner, 59 T.C. 312, 317
(1972).
As previously discussed, we believe there were some personal
or recreational aspects to petitioner’s Reliv activity, such as
attending weekly meetings and contacting family members. In
addition, as a Reliv distributor, petitioner presumably would
enjoy a discount for Reliv products, similar to the discount that
motivated his brother and his son to become involved as Reliv
distributors. The record indicates that petitioner was a long-
time user of Reliv products. It would appear that the ability to
purchase Reliv products at a discount was a significant personal
benefit to petitioner. This factor favors respondent.
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