Michael D. and Suzan L. Storer - Page 6

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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 @               

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Last modified: November 10, 2007