Earl L. Miller and Nancy B. Miller - Page 4

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                  When traveling, petitioner or her husband normally take                               
            photographs.  She owns various pieces of 35mm single lens reflex                            
            camera equipment that she uses in connection with her writing                               
            activity.  She does not carry all of her photographic equipment                             
            on all of her trips.                                                                        
                  Petitioner has amassed an inventory of 9,000 slides which                             
            she intends to market at some future point in time.                                         
            Occasionally, petitioner includes individual slides or                                      
            photographs with articles submitted for publication.  Some                                  
            publishers pay a higher fee for articles that include                                       
            photographs.                                                                                
                  During 1993, petitioners attended the Second Annual Seminar                           
            at Sea (the cruise) from July 31 to August 13.  The cruise was                              
            held aboard the Royal Princess, Princess Cruise Line's flagship.                            
            The ship departed from Southampton, England, sailed to ports in                             
            Scandinavia and Russia, then returned to England.  As part of the                           
            cruise, petitioners took ancillary land tours to St. Petersburg,                            
            Moscow, and Copenhagen.  Following the cruise, petitioners                                  
            remained in England for two additional days, touring London and                             
            Bath.                                                                                       
                  The cruise was advertised as an educational seminar hosted                            
            by travel writing and photography experts Carl and Ann Purcell.                             
            Mrs. Purcell was unable to attend, and was replaced by Bill                                 
            Pekela, General Manager of Technical and Professional Services                              





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