- 11 - nothing more than a conscious attention to detail. Golanty v. Commissioner, supra at 430. Petitioner had extensive experience with accounting work, and it is natural to expect that she would apply that experience to her photography activity. Moreover, it does not seem that the records were kept for the purpose of cutting expenses, realizing profits, or evaluating the overall performance of the operation. Rather, it appears that the principal purpose of petitioner's records was to substantiate claimed deductions from income for tax purposes. Analysis of petitioner's records reveals that her activity was operated with little or no regard for the level of expense incurred in relation to the small amount of income yielded by the activity. Petitioner frequently incurred costs for restaurant meals and groceries in connection with her photography activity, explaining that she and the people she met had to eat anyway, and so would meet over a meal to discuss photography. We note that many of petitioner's clients during the years in issue were coworkers, friends, and family, and petitioner has not convinced us that many of the meals did not have significant personal or social aspects for her. Indeed, the meetings and other contacts with persons in connection with her photography activity recorded by petitioner largely appear consistent with ordinary social activities. Petitioner has not established that she did not use her photography activity as a means of deducting personal expensesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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