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See sec. 1.183-2(b)(3), Income Tax Regs. However, we regard
petitioners’ estimate as excessive. See Kropp v. Commissioner,
T.C. Memo. 2000-148 (“As a trier of fact, it is our duty to
listen to the testimony, observe the demeanor of the witnesses,
weigh the evidence, and determine what we believe.”); see also
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986) (“we are not
required to accept the self-serving testimony of petitioner * * *
as gospel.”); cf. Diaz v. Commissioner, 58 T.C. 560, 564 (1972).
In any event, many individuals devote considerable time to their
hobbies and similar activities.
In view of the foregoing, we hold that petitioners are not
entitled to deduct the losses from their Amway activity for the
years in issue. However, pursuant to the provisions of section
183(b), petitioners are entitled to deduct expenses to the extent
of gross income from their Amway activity.
We have carefully considered all of the contentions made by
petitioners for a holding contrary to that expressed herein, and
to the extent not touched on above, we find such contentions to
be unpersuasive.
To give effect to the foregoing,
Decision will be entered
under to Rule 155.
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