Michael D. and Suzan L. Storer - Page 18

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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             

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Last modified: November 10, 2007