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enthusiasm of these weekends but was not willing explicitly to
classify them as pleasure. Sometimes petitioners went
separately, partly because of his work schedule and partly
because they were separated during some portion of the years in
issue. Petitioners’ expenditure of substantial funds and
attendance at numerous Amway conventions and seminars, near and
far, even though their financial return from Amway was nil, and
had been minimal during many years of Amway experience, suggests
an element of pleasure or recreation in the participation. See
Nissley v. Commissioner, supra, where we commented about this
aspect of the Amway organization as follows: “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.”
Based upon the objective facts and the totality of the
circumstances, petitioners’ contention that their Amway activity
was engaged in for profit is unsupportable. They had extensive
experience with Amway. By the years in issue they knew or surely
should have known that they were not going to make money at
Amway. They benefited to some extent by deducting automobile and
legal and other necessary expenditures that otherwise would be
nondeductible, and they participated in the excitement of the
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