- 5 - for the Photographic Division of Nikon. Petitioners met with Mr. Purcell and Mr. Pekela informally at least twice a day to discuss style and technique. Over the 2-week course of the cruise, there was a total of 5 1/2 hours of formal instructions. During the ancillary land tours, petitioners took approximately 900 photographs. In a document prepared by petitioner and submitted to respondent prior to the issuance of the notice of deficiency, petitioner indicated that the purpose for the cruise "was to study and apply [petitioners'] knowledge [in] obtaining excellent photographic shots for future photography stock of European ports." Petitioner originally considered the cruise to be educational. However, she was not satisfied with the extent of formal instructions given during the cruise and subsequently decided that the cruise was more for research purposes than educational purposes. The total cost of the cruise, including meals, airfare, and ancillary land tours, was $12,067.75. Petitioner had published one article related to the cruise, for which she was paid $150. Petitioner maintains detailed records of her expenditures, the amounts of which are undisputed by respondent. She maintains a separate log book and a separate bank account for her writing activity. She pays for a majority of the expenses related to her writing activity via credit card, the bills from which are usually paid from petitioners' personal joint checking account.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011