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(9) the presence of elements of personal pleasure or recreation.
No single factor, nor the existence of even a majority of the
factors, is controlling. Golanty v. Commissioner, supra at 426;
Dunn v. Commissioner, 70 T.C. 715, 720 (1978), affd. 615 F.2d 578
(2d Cir. 1980).
Respondent has successfully litigated the section 183 "for
profit" issue in other cases involving Amway distributorships.
Specifically, previous cases demonstrate that there are signifi-
cant elements of personal pleasure attached to the activities of
an Amway distributorship. See Rubin v. Commissioner, T.C. Memo.
1989-290. Further, an Amway distributorship presents taxpayers
with opportunities to generate business deductions for essen-
tially personal expenditures. See Elliott v. Commissioner, 90
T.C. 960 (1988), affd. without published opinion 899 F.2d 18 (9th
Cir. 1990); Poast v. Commissioner, T.C. Memo. 1994-399. With
this in mind, we consider the facts of the case herein.
Ordinarily, respondent initially takes a litigating position
on the date she files her answer to the petition. Huffman v.
Commissioner, 978 F.2d 1139, 1148 (9th Cir. 1992), affg. in part
and revg. in part on other grounds and remanding T.C. Memo.
1991-144. Therefore, we begin by reviewing the facts reasonably
available to respondent on December 22, 1995, the date she filed
her answer to the petition, in order to evaluate the reasonable-
ness of respondent's position. Id. Petitioners had suffered
yearly losses from 1987 to 1994, which, as a general trend, grew
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