Deborah Joyce Windisch - Page 13

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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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