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I would have somebody to show the plan to”. During the
Thanksgiving holiday, from November 25-28, 1999, petitioners
drove to Chattanooga, Tennessee, where petitioner’s parents live.
Again, petitioner stated: “Because I used my business car, I
made sure that I prospected and tried to--made contacts with
people in Chattanooga”. Petitioners did not recruit any downline
distributors on these trips, and there is no evidence that they
sold any Amway products on these trips. They simply made a few
perfunctory calls on unresponsive individuals and claimed
deductions for the personal trip.
At the Amway conferences, petitioners repeatedly met with
many of the same people from the Florence organization, and many
of those trips occurred during holiday weekends such as the New
Year and the Fourth of July. Petitioners testified that the
purpose of the Amway conferences was training, but they did not
explain why they felt it was necessary to attend so many training
seminars during their third and fourth years into their Amway
activity.
Petitioners repeatedly used their Amway activity as an
attempt to mask obviously personal expenses as deductible
business expenses. In effect they attempted to live a deductible
lifestyle. The conferences at times of the year associated with
vacation and recreation are consistent with this same mindset.
Most importantly, petitioners reported no significant revenue
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