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developing more accessible to amateur consumers, this newfound
ability for recreational “photogs” to take and develop their own
pictures has not changed the demand for quality, professional
photography. If anything, the availability of high-quality
digital cameras has made the consumer more astute regarding both
resolution and composition aesthetic when selecting a
professional photographer. To this end, had petitioners invested
more resources into education and training or sought professional
evaluation of their skills, we would be more convinced that their
activity was engaged in with the objective of making a profit.
Petitioners argue that the income they earned in their
respective full-time jobs in 2000 and 2001 is irrelevant because
petitioners could not use their wages to pay for any of their
photography-related expenses but instead, used credit and gifts
from friends and family. Petitioners claim that their wages were
almost completely exhausted by their household bills, mortgage,
and taxes. With expenses totaling $23,000 in the years in issue,
we are doubtful that petitioners did not apply any of their wages
to this amount. Moreover, we note that, if petitioners indeed
incurred debt of $23,000, the fact that they only took in $2,000
in sales supports our conclusion that petitioners’ activity in
these 2 years was not engaged in with the objective of making a
profit.
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Last modified: November 10, 2007