Michael D. and Suzan L. Storer - Page 17

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          in the years in issue because they sold a considerable portion of           
          their “analog” equipment while upgrading to newer, digital                  
          technology.  Petitioners claim that their losses are further                
          justified by the difficult economic conditions which plagued                
          large “analog” photography businesses, such as Eastman-Kodak, as            
          more consumers switched from “analog” to digital photography.               
               We do not find credence in petitioners’ arguments.  First,             
          petitioners do not claim to be engaged in the business of selling           
          photography equipment but, rather, taking photographs.  Second,             
          although we acknowledge the phenomenal growth in digital                    
          photography throughout the past decade, petitioners were not in             
          the business of developing other people’s photographs.                      
          Petitioners purported to be professional photographers.  The                
          effect of the digital photography boom on businesses such as                
          Eastman-Kodak resulted from consumers’ choosing to develop their            
          photographs at home rather than use traditional film developing             
          services.  It did not affect the demand for quality professional            
          photography services for the very types of portraiture and event            
          coverage which petitioners claimed was their focus; namely,                 
          weddings, corporate prints, and senior portraits.  Similarly, the           
          boom in home developing did not affect the specialized services             
          that are often the hallmark of professional photographers, such             
          as portrait sittings, albums, restorations, DVDs, and videos.               
          Again, while the phenomenon of digital photography has made home            

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