- 19 - “perform many, menial chores” and “has had to do many forms of marketing including cold calls that can be unpleasant at times.” While petitioners claim that they should not be required to suffer as “a prerequisite to deductibility,” we cannot help wondering how petitioners engaged in their activity with a profit objective if they were opposed to performing the tasks essential to business success; namely, marketing and sales calls. Finally, although we concede that on its face, petitioners’ photography activity did have some of the characteristics of a business, we find these characteristics insufficient to demonstrate that their activity was carried on for profit. Therefore, on the basis of all of the evidence in the record, we conclude and hold that petitioners did not conduct their photography-related activity in either 2000 or 2001 with a profit objective within the meaning of section 183. Accordingly, petitioners are not entitled to the deductions claimed on their Schedules C for the years in issue. Section 6662(a) Penalty Respondent determined that petitioners are liable for the accuracy-related penalty provided by section 6662(a) for each year in issue. Section 6662(a) imposes a 20-percent penalty on the portion of an underpayment of tax that is attributable to, inter alia, negligence or disregard of rules or regulations. The term “negligence” includes any failure to make a reasonablePage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007