Michael D. and Suzan L. Storer - Page 11

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          activity may appreciate in value; (5) the success of the                    
          taxpayers in carrying on similar or dissimilar activities; (6)              
          the taxpayers’ history of income or loss with respect to the                
          activity; (7) the amount of occasional profits; (8) the financial           
          status of the taxpayers; and (9) whether elements of pleasure or            
          recreation are involved.  Golanty v. Commissioner, supra at 426;            
          sec. 1.183-2(b), Income Tax Regs.                                           
               Based on our consideration of these factors and in the light           
          of the copious record in this case, we conclude that petitioners            
          have not demonstrated that their photographic activity was                  
          carried on with an actual and honest objective of making a profit           
          in the taxable years at issue.  In reaching our conclusion, we              
          view the following elements as being most persuasive:                       
          Manner in Which the Taxpayers Carried On the Activity                       
               We believe that the manner in which petitioners carried on             
          their photography activity does not support a finding that it was           
          engaged in for profit.  In 2001, petitioners only made 14 sales             
          and of these, at least one-half were made to buyers identified on           
          petitioners’ records by first name only.  Several other entries             
          were identified by only the buyer’s first name plus the words “at           
               Petitioners testified that the 14 sales in 2001 were not               
          reflective of their manner of operations because they “actually             
          solicited to hundreds of potential customers” at various craft              

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