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more profitable. Indeed the record presented at trial suggests,
at least with respect to Renaissance, that Mrs. Smith ceased
selling for the company because it was shut down by the Kansas
State authorities.
The business plans and goal sheets that Mrs. Smith prepared
do not support a conclusion that she was operating her direct
marketing activities with the actual and honest goal of making a
profit. These business plans were largely prepackaged by the
company for which she was selling and were full of vague and
unsupported puffery concerning the amount of sales she hoped to
make. These purported business plans and goal sheets lacked any
analysis of how these vague goals might be achieved, what startup
costs were involved, how long it would take to recoup those
startup costs, what type of market there was for the products she
was selling, or other types of analysis one might expect to find
in a genuine business plan. While Mrs. Smith testified that she
did these types of analysis, there is nothing to substantiate her
self-serving testimony. See Tokarski v. Commissioner, 87 T.C.
74, 77 (1986) (noting the Court is not required to accept a
taxpayer’s self-serving testimony in the absence of corroborating
evidence).
In short, we find that the manner in which Mrs. Smith
conducted her direct marketing activities, including the
maintenance of records without any underlying analysis of how to
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