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Having considered all of the relevant facts and
circumstances, we conclude that petitioners are not entitled
to the deductions here in dispute because their Amway
distributorship was not a trade or business within the meaning
of section 162(a) for either year in issue. Respondent’s
determinations in this regard are, therefore, sustained.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011