Michael D. and Suzan L. Storer - Page 19

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          Elements of Recreation                                                      
               In sum, we believe that petitioners engaged in their                   
          photography activity for the principal purpose of providing Mr.             
          Storer with the opportunity to take up a pleasurable hobby to               
          reduce his stress and anxiety.  It is evident from the                      
          photographs showing the areas in their home used for this                   
          activity that petitioners took great care and expense in setting            
          up a pleasant and well-stocked workspace.  Photography, however,            
          is highly subjective, and in great part, the success of a                   
          photography business is dependent on both the skill and talent of           
          the photographer and the marketing and reputation cultivated                
          therefrom.  We are perhaps ultimately persuaded by petitioners’             
          decision to forgo any formal training or education in photography           
          in lieu of reading photography and trade magazines, and picture             
          books featuring works by famed landscape photographer Ansel                 
          Adams.  While it is beyond our purview to comment on Mr. Storer’s           
          ability or potential, we think it unlikely, barring an                      
          extraordinary talent, to become Ansel Adams through self-study.             
          Moreover, we believe that Mr. Storer, through educating himself             
          primarily with trade magazines that feature the most current                
          technologies, was compelled to purchase and, ultimately,                    
          gratified by his acquisition of extremely expensive equipment.              
          Finally, we note that at the end of petitioners’ presentation               
          prepared for the Court, Mr. Storer lamented that he had to                  

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Last modified: November 10, 2007