Earl L. Miller and Nancy B. Miller - Page 5

                                                - 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