Larry Minnick and Charla Minnick v. Commissioner - Page 13




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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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