- 2 - 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: Penalty 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. Background 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007