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Watsonville, California. Petitioner's previous jobs also
involved accounting work. Also during the years in issue,
petitioner held a part-time position as a telephone bill
collector with the Credit Bureau of Santa Cruz County, working as
few as 12 hours to as many as 17 hours per week. Petitioner
worked at her part-time job from 5:30 p.m. until as late as 10
p.m. Monday through Thursday and from 9:30 a.m. until as late as
4 p.m. Saturday.
Petitioner was involved in photography prior to the years in
issue. Members of her family had worked in the photography field
as well. Petitioner photographed, inter alia, weddings, family
reunions, and graduations. Petitioner also made portraits and
photographed rock bands and musicians. She did not charge for
her photography work until 1987 and, until then, did not treat
the activity as a business for tax purposes. Beginning with her
1987 Federal income tax return, she included the activity on
Schedule C of her returns, claiming losses for each of the
taxable years 1987, 1988, and 1989.
Petitioner did not maintain a dark room and sent her film to
a processing lab for developing. Petitioner did not have formal
training in photography during the years in issue. Petitioner,
however, had the quality of her photographs analyzed and
critiqued. During 1991, petitioner joined the Professional
Photographers of California and the Professional Photographers of
the Monterey Bay Area (PPMBA), which held monthly meetings at
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