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large table, desk, computer, and bureau in a spare room adjacent
to their bedroom.
From 1998 through the years in issue, Mr. Storer suffered a
series of health setbacks requiring him to take off substantial
time from his job at General Motors.
Petitioners maintained neither a separate bank account for
their photography activities nor a separate phone line for
customers. Although petitioners had purchased a separate
insurance policy for their cameras and developing equipment in
the early 1990s, they combined this policy into their homeowners’
insurance in 1999.
In 2001, petitioners made 14 sales transactions. These
sales were made to friends and Mr. Storer’s co-workers at General
Motors.1 The nature of petitioners’ sales in 2002 is unknown.
In preparation for trial, petitioner prepared a portfolio of
photography brochures, listing prices, and packages. None of the
materials contained in the portfolio were created in or used as
marketing during the years in issue. This portfolio included
examples of the types of landscape photographs that Mr. Storer
had taken from such places as Yosemite National Park, North
Dakota, Washington, Puerto Vallarta, Aruba, and San Juan. The
1 Petitioners provided a summary of their 2001 invoices.
This 3-page summary lists 7 of the 14 buyers by first name only
as: “Jim; Hall; Steve; Al @ GM; Gary @ GM; ‘Lady’ @ GM; Bob @
GM.”
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Last modified: November 10, 2007