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developing his own photographs sometime in the early 1990s on his
physician’s advice that he take up a hobby to help him cope with
periodic episodes of depression. At that time, Mr. Storer, who
holds a high school diploma, was working in the repair shop at
General Motors.
Mr. Storer purchased many books on photography and film
developing, as well as photography magazines, some film cameras,
and film developing equipment. Mr. Storer had not taken any
instruction in photography prior to and including the taxable
years at issue. Mr. Storer did not have his skills as a
photographer or the quality of his photographs analyzed or
critiqued, or have his work juried, prior to or during the years
at issue.
While he continued to take and develop his own pictures, Mr.
Storer became interested in photographic restoration, and he
purchased the equipment and supplies necessary to restore old
photographs. Sometime in the early 1990s, Mr. Storer first
offered photographic restoration services to family members,
friends, and co-workers. Around this time, he decided to try
selling some framed landscape photographs he had taken and
developed from earlier trips to landmarks such as Yosemite
National Park. Around this time, petitioners set up a makeshift
photography studio and darkroom in the basement of their home.
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Last modified: November 10, 2007