Michael D. and Suzan L. Storer - Page 12

                                       - 11 -                                         
          and art shows during the years at issue.  We note, however, that            
          in a detailed calendar for 2001, which was submitted as an                  
          exhibit and on which petitioners testified that they recorded all           
          of the time spent on training, marketing, and sales, there is not           
          one entry of any craft or arts show.  There are also no entries             
          showing preparation for any craft or arts shows.                            
               Although petitioners reported sales of $855 in 2001, there             
          is no evidence that petitioners actually made any sales in 2001             
          or to whom these sales were made.                                           
               Petitioners did not use a separate bank account or telephone           
          number for their activity, and the insurance held on all of their           
          photography equipment was incorporated into their homeowner’s               
               Mr. Storer testified that, as one example of the “highly               
          professional nature in which he carried on his business,” he only           
          used business cards printed by a commercial printer rather than             
          the type printed on an ink-jet printer “with those little                   
          perforations on the sides.”  Upon examination of the two business           
          cards provided by petitioners with their exhibits, however, it is           
          clear that the cards have both the visible dot-matrix quality               
          akin to those printed on an ink-jet printer as well as perforated           
               Although petitioners kept very extensive and detailed                  
          records of their expenses, we believe that these records were               

Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next 

Last modified: November 10, 2007