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“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 reasonable
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