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Finally, this Court has observed that “there are significant
elements of personal pleasure attached to the activities of an
Amway distributorship” and that “an Amway distributorship
presents taxpayers with opportunities to generate business
deductions for essentially personal expenditures.” Brennan v.
Commissioner, T.C. Memo. 1997-60; see also sec. 1.183-2(b)(9),
Income Tax Regs.; cf. sec. 1.183-2(b)(8), Income Tax Regs.,
regarding the reference to “personal or recreational elements”
quoted above.
In the present case, the personal dimensions of petitioners’
Amway activity indicate that such activity was not engaged in for
profit. The fact that petitioners have “no intentions of getting
out of * * * Amway” underscores this conclusion.6
The record suggests that petitioners enjoy the same
congenial sense of family and the same gratifying motivational
feeling from participating in their Amway activity as do many
other individuals who remain committed to Amway. The record also
suggests that Amway constitutes an important part of petitioners’
social life.
In addition, during the years in issue, petitioners attended
Amway conventions and seminars on a regular basis in cities such
6 Moreover, a taxpayer who intends to pursue an activity
“no matter what” cannot be said to pursue the activity in a
businesslike manner. Sec. 1.183-2(b)(1), Income Tax Regs.,
discussed supra.
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