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frequently visiting family members who were also involved in
Amway. We find that this factor remains neutral.
As previously stated, more weight must be given to objective
facts indicating a profit objective than to petitioners’
statement of intent. Dreicer v. Commissioner, supra. After
considering the objective factors detailed above, we find
especially relevant the manner in which petitioners carried on
the Amway activity and petitioners’ history of losses and lack of
profits. We find from these and the other objective facts in the
record that petitioners did not have an actual and honest intent
to profit from the Amway activity in 1996 and 1997.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011