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Petitioner also had limited time to devote to her
photography activity, inasmuch as she was employed full time as
an account clerk and worked as few as 12 hours to as many as 17
hours per week, from Monday through Thursday during the evening
and during the day on Saturday, as a telephone bill collector.
Although petitioner claimed to devote to photography much of the
time that was not occupied by her jobs, we are not convinced that
petitioner's motivation was not primarily social and recreational
in taking meals with coworkers, friends, and relatives, and in
associating with the rock bands and musicians she photographed
during the time she pursued her photography activity. Petitioner
also has not shown that any of the assets used in her photography
activity, or the photographs that she took, would appreciate in
value, or that she was successful in carrying on similar or
dissimilar activities.
Petitioner has consistently incurred losses in her
photography activity from 1987, the first year she treated it as
a business for tax purposes, through 1992, the last year in
issue, and has never reported a profit from the activity. For
each year in issue, petitioner reported a substantial loss that
was apparently attributable to her photography activity.3 For
1990, petitioner received approximately $380 from her photography
3 Petitioner has not attempted to show whether any of the
expenses claimed on the Schedules C related to the income
reported on those schedules that was realized from her activities
besides photography.
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