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