- 13 - Golanty v. Commissioner, supra at 427; Nissley v. Commissioner, T.C. Memo. 2000-178. Seemingly, petitioners’ only plan to reverse the years of losses always was based on the premise that their people and sales skills would improve and that they would be able to persuade other downline distributors to join their network. Petitioners maintained their respective employments during the years in issue. Petitioners worked approximately 87 to 100 hours per week at their respective jobs, and spent only 15 to 20 hours per week on Amway. From their employment, petitioners reported wages of $96,389 in 1999 and $98,949 in 2000. Petitioners were able to use the losses from their Amway activity to offset income earned from their employment. We believe petitioners received enjoyment from the Amway activity, and we cannot overlook the personal and social aspects of their trips for which they claimed significant travel expenses. They regularly used Amway activities as a device to deduct personal expenses as business expenses. For example, on two occasions, around March 26 and August 22, 1999, petitioners drove to Champaign, Illinois, where their daughter was attending the University of Illinois. On the August 22 trip, petitioner drove his daughter to school for the start of the fall semester. He explained: “The fact that I was going to use my business car to transport [personal] effects down there meant I made sure thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011