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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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