- 13 - activities in 2000 and 2001, and not with what petitioners have or have not done in subsequent years. Time and Effort Expended by the Taxpayers The numbers of hours spent cultivating his activity, as testified to by Mr. Storer, is not only dubious but, if accurate, is grossly inverse to the sales resulting from his efforts. Mr. Storer claimed that he spent nearly 1,200 hours working on his activity in 2001, in addition to his full-time position at General Motors. If this claim was accurate, Mr. Storer would have had to spend an average of more than 3 hours a day,3 every day, on his photography, in addition to his full-time work, commuting to and from his workplace, and eating and sleeping. As evidence of his daily activities, Mr. Storer submitted as an exhibit a pocket calendar for 2001 in which he purportedly handwrote the time he spent on his photography activity each day. Our examination of this calendar has led us to conclude that petitioners’ claims as to the time spent on the activity are not accurate. First, we believe neither that the calendar was made contemporaneous to the dates as recorded nor that it was an accurate accounting of petitioners’ time. For support of this conclusion, we look to several instances where the calendar contains entries for dates that simply do not exist. 3 (1,200/365 = 3.29 hours)Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: November 10, 2007