-6-
constitutes all of petitioner’s books from his videotape
activity.3
Petitioner has devoted one room in his home to his videotape
activity. Petitioner’s reference items in that room include:
(1) Reference books such as The Technique of Film Editing, and
The Technique of the Film Cutting Room, (2) instruction manuals
for the video and audio equipment, and (3) numerous other
magazines and publications.
Petitioner has at least 30 video projects, for a total of at
least 75 tapes, covering the topics described in tables 1 through
4, infra.
Travel Videos
Petitioner and his wife (she died in 1991) vacationed
throughout the world. Petitioner videotaped and sold copies of
the videotapes of these vacations primarily to people who
petitioner and his wife either met on their excursions or
traveled with. Table 1 summarizes these videotapes.
Table 1
1. Golden Odyssey Cruise - This two-tape set covers a
cruise to the Mediterranean on The Royal Cruise
Line. Petitioner sold six copies of the video for
a total of $240.
3 So stipulated. Evidently petitioner’s expenses are not
recorded in the form of books but presumably are in the form of
records, which are sufficiently complete and accurate so as to
enable the parties to stipulate the correctness of all the
expense amounts reported on petitioner’s Schedule C for each year
in issue. Supra note 2.
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