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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)
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