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4. Expectation That Assets May Appreciate in Value
Petitioner does not contend and the record does not suggest
that there are any assets involved with petitioner’s Reliv
activity that may appreciate in value. We view this factor as
neutral.
5. Success in Carrying On Similar Activities
Insofar as the record reveals, petitioner has engaged in no
other activities similar to his Reliv activity, by which we might
evaluate his success in those other activities. We view this
factor as neutral.
6. History of Income or Losses
Petitioner has never realized a profit from his years of
Reliv activity. Rather, for the year at issue and the preceding
5 years, petitioner’s claimed operating expenses for his Reliv
activity exceeded his revenues therefrom by factors ranging from
about 10 to 24. Petitioner suggests that these losses are due to
his Reliv activity’s being in a startup phase; he suggests that
it is in the nature of the Reliv business to experience a
dramatic profit spike at some point. Petitioner offered no
concrete information, however, to convince us that his
expectation of a future revenue spike is more than wishful
thinking. This factor favors respondent.
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Last modified: March 27, 2008