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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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