Michael D. and Suzan L. Storer - Page 14

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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            
               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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