Michael D. and Suzan L. Storer - Page 3

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          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
               Respondent determined deficiencies in and penalties to                 
          petitioners’ Federal income taxes as follows:                               
                    Year      Deficiency            Sec. 6662(a)                      
                    2000      $4,487                   $898                           
                    2001   $2,832                      $567                           
               The issues for decision are whether petitioners’ photography           
          activity constituted an activity not engaged in for profit within           
          the meaning of section 183 during the years at issue and whether            
          petitioners are liable for the accuracy-related penalties                   
          provided by section 6662 for the years at issue.                            
               The stipulation of facts and the attached exhibits are                 
          incorporated herein by reference.  At the time the petition was             
          filed, petitioners resided in Miamisburg, Ohio.                             
               During the years in issue, petitioners were both employed in           
          full-time jobs.  Petitioner-husband (Mr. Storer) worked as a                
          repairman for General Motors, Inc., and petitioner-wife (Mrs.               
          Storer) worked as a receptionist and bookkeeper for Harding ESE,            
          Inc.  Petitioners earned total wages of $92,639 and $96,191,                
          respectively, during the years in issue.                                    
               Mr. Storer developed an affinity for photography as a young            
          person.  However, he first started habitually taking and                    

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Last modified: November 10, 2007