Randall B. and Kay F. Ollett - Page 16

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          from their Amway activity and no reason for them to believe they            
          ever were going to have significant revenue from this activity.             
               Petitioner testified that he joined Amway with a profit                
          motive, and he may have had that subjective intent initially.               
          However, as previously stated, more weight must be given to                 
          objective facts indicating a profit objective than to                       
          petitioners’ subjective intent.  Because of the manner in which             
          petitioners carried on their Amway activity, the lack of revenue,           
          and the size and persistence of the continuing losses, we hold              
          that petitioners’ Amway activity during the years in issue was              
          not carried on for profit within the meaning of section 183, and            
          petitioners are not permitted to deduct their losses from that              
          activity.                                                                   
               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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