- 10 - “Business Expenses” incurred in 1996 and 1997, and a chart of “Office Expense” from 1996. They maintained and produced monthly calendars reflecting both Amway-related entries and personal entries for both 1996 and 1997. Also, Ms. Ingram claimed that they opened a bank account for their Amway activity. Nevertheless, we conclude that petitioners’ overall approach to their activity was not businesslike. See sec. 1.183-2(b)(1), Income Tax Regs. The records that petitioners produced do not reflect details concerning their Amway activity, such as products sold, clients, or downline distributors. In addition, the goals do not provide any indication of how petitioners planned to achieve the points and commissions, or how to find the customers. Despite being given ample opportunity to produce relevant business records, petitioners failed to do so, and they failed to offer an explanation for their absence. For example, petitioners failed to produce a copy of their business plan and bank records. Petitioners produced an “Office Expense” chart for 1996, but not for 1997, and did not offer any supporting bills or proof of payment of any of the expenses. Petitioners did not retain paper copies of the quarterly, semiannual, and annual reports of income and expenses that they purportedly kept. Petitioner explained that when their computer upgrade crashed, they lost all reports. We are skeptical that all data that went into the reports was irretrievably lost. Petitioners’ inability to produce thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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