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has no training as a historian and no expertise concerning the
Civil War.
Petitioner made no advance arrangements to profit from his
proposed writings during the summer travel. He did not employ a
literary agent or contact publishers or magazines in advance.
Instead, during the trip he prepared a series of pieces,
apparently written quickly, since they are replete with spelling
and punctuation errors, and then submitted the unsolicited
articles to national magazines such as the National Geographic.
All the articles were rejected, some with the explanation that
the publication did not accept unsolicited material. Petitioner
did not receive any revenue at all from his writing with respect
to his travels in 1997.
Petitioner does not have background or training as a writer
or historian. He did not prepare for the activity in issue in a
businesslike way. He did not spend substantial time preparing or
marketing the writing. He has never supported himself by his
writing and has no history of success in professional writing
activities. The activity resulted in no income and substantial
expenses. Although petitioners are not wealthy people, they have
income from wages. During the year in issue, petitioners
reported wages of $44,559 and unemployment compensation of
$5,980. They claimed tax benefits by offsetting a loss of
$12,732 from their Schedule C activities against their income
from other sources.
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