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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 expenses
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