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portfolio also included wedding photographs and photographs of
individuals and pets, some of which are dated from the late 1970s
and early 1980s, and none of which were taken during the taxable
years in issue. Petitioners attached a business card to the
portfolio which reads: “Michael Storer Photographs, 1150 E.
Lindsey Ave., Miamisburg, Ohio 45342, Photo Restorations & More.”
The address and phone number listed on petitioners’ card are
those of their personal residence.
Beginning with their 1993 Federal income tax return,
petitioners included the photography activity on Schedules C,
Profit or Loss From Business, of their returns.
Petitioners reported gross receipts and claimed losses from
a 7-year period of the photography activity from 1996 through
2002, while maintaining full-time employment, as follows:
Year Gross Receipts Total Expenses Profit or/(Loss)
1996 $1,060 $14,402 ($13,342)
1997 316 13,375 (13,059)
1998 435 20,439 (20,004)
1999 1,366 15,027 (13,661)
2000 1,474 21,421 (19,947)
2001 855 16,050 (15,195)
2002 1,575 9,586 (8,011)
Totals $7,081 $110,300 ($103,219)
For the years in issue, petitioners claimed the following
deductions on their Schedules C:
Item 2000 2001
Advertising $153 $98
Car and truck 112 202
Depreciation 13,350 8,215
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