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producing photography exhibitions as a means of earning revenue.
To do so, he believed he needed to enhance his reputation as a
photographer. To that end, by 1992 petitioner was spending 60 to
80 hours per month building his own photography portfolio. He
began entering his works in exhibitions, winning numerous
photography awards and achieving substantial acclaim.
In 1993, petitioner was asked to take over the production
and management of an existing photography exhibition, the
Wisconsin International Exhibition of Photography, and he also
assisted the Wisconsin Area Camera Club Organization (WACCO) in
producing an existing international photography exhibition.
In 1994, petitioner took over production of the exhibition
for WACCO. In each of the years 1993, 1994, and 1995, petitioner
produced one exhibition. Beginning in 1996 and continuing to the
present, petitioner has produced four exhibitions each year,
devoting approximately 800 to 1000 hours each year to this
activity.
Petitioner’s activities in producing photography exhibitions
include, among other things, advertising the exhibition, drafting
and printing brochures, compiling mailing lists, inviting
photographers to participate, sending and receiving applications,
recruiting judges, creating a catalog of entries, obtaining
sponsors, purchasing awards, and performing marketing and
accounting functions. These activities are a “year-round
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