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stake in petitioners’ retail and downline sales.”); Ogden v.
Commissioner, supra (“Amway distributors may be biased when
discussing Amway because they have a natural desire to advance
the organization and/or obtain income from a downliner.”).
Petitioners have steadfastly refused to seek counsel from
disinterested third parties, even though the advice they have
received from interested Amway individuals has done nothing to
reverse petitioners’ history of uninterrupted and substantial
losses. Furthermore, the record suggests that the “advice”
petitioners received has consisted of little more than
platitudes, generalities, and encouragement to “stick with it”.
Also noteworthy is the fact that after her resignation from
Administar Information Technologies in mid-1994, Mrs. Nissley was
able to generate immediately a net profit as a self-employed
business consultant, earning $23,193 based on gross receipts of
$31,735 and total expenses of $8,542, for the last 6 months of
1994. By contrast, in their Amway activity, petitioners have
incurred nothing but substantial losses for 8 consecutive years.
Third, section 1.183-2(b)(8), Income Tax Regs., provides in
part that “Substantial income from sources other than the
activity (particularly if the losses from the activity generate
substantial tax benefits) may indicate that the activity is not
engaged in for profit especially if there are personal or
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