- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011