- 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 that
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