Michael D. and Suzan L. Storer - Page 4

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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