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there was a business purpose for the foregoing expenditures, she
has not shown that they did not have significant personal aspects
as well.
Other circumstances also suggest that petitioner's
photography activity was not operated in a businesslike manner.
It does not appear that petitioner made any significant changes
in the manner in which she operated her activity, such as
reducing expenses, in an effort to achieve profitability during
the years in issue. Those circumstances, as well as others in
the record, such as the fact that petitioner generally did
photography for coworkers, friends, and relatives, indicate to us
that personal, rather than business, considerations influenced
the manner in which petitioner conducted her photography
activity.
Although petitioner claims that she learned about pricing
her services as a photographer from attending lectures given at
meetings of the PPMBA, and changed her practices as a result, it
does not appear that the change caused any significant
improvement in the financial results of the activity. Moreover,
although petitioner claimed to have a mentor, that person's
advice appeared to concern the technical quality of her
photography rather than the business aspects of the activity. We
are not persuaded that petitioner made any concerted effort to
obtain advice as to how to make her photography activity
profitable.
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