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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.
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