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process”, commencing about a year before the opening of an
exhibition with the assembly of documentation to request
recognition by the Photographic Society of America and concluding
about a year later with the production of a catalog and returning
entries submitted.
JJT pays all the costs associated with the exhibitions it
produces and is the sole recipient of the revenues generated.
Beginning in 1994 and continuing to the present, petitioner has
consistently realized modest net profits from producing the
photography exhibitions. Petitioner has plans to increase JJT’s
revenues by increasing the number of exhibitions he produces each
year and by increasing entry fees. In addition, petitioner has
been involved in efforts by the Photographic Society of America
to set standards for “electronic exhibitions”, which he
anticipates would reduce his operating costs for exhibitions and
thus increase his net profits. Petitioner has also been asked to
begin teaching photography to select groups, and he anticipates
that such teaching opportunities will generate significant
additional revenues. He also anticipates that he will continue
to offer his prints for sale, although he does not expect the
proceeds to be substantial.
On his Federal income tax returns, petitioner reported net
losses from JJT’s activities every year from the inception of JJT
in 1982 until 1995, when JJT reported a small profit. Since
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Last modified: May 25, 2011