- 12 - petitioner's failure to consider whether the income that could be generated by a particular trip would be in excess of the expenses related to the trip. In fact, the income-producing potential of a particular trip seemed to be of little concern to petitioner. It appears that petitioner would first decide upon a destination and spend whatever was necessary to travel there, regardless of the amount of income that she could objectively expect to earn from the sale of articles resulting from the trip. This is obvious during the years in issue from the relatively small amount of income that petitioner received on a per-article basis. For example, in 1993 and 1994, petitioner traveled to Las Vegas, deducting expenses of $907.52 and $934.96, respectively. Even though she sold three articles that resulted from the trips, she recovered less than one-third of the expenses deducted. Similar circumstances occurred regarding petitioner's travels to Miami, Milwaukee, and Disney World. With few exceptions, petitioner did not sell an article that generated more income than the expenses attributable to the related trip. Furthermore, the decision to deduct the expenses of a particular trip was sometimes made after the fact. For example, petitioners took a trip to Disney World in 1994, for which they incurred expenses of $977.51. Although petitioner had not planned on writing any articles about Disney World or contacted any editors prior to the trip, upon returning home she decidedPage: 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