Earl L. Miller and Nancy B. Miller - Page 12

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            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 decided                              





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