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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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