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properties (or, in other words, enough hours to meet the 750-hour
requirement of section 469(c)(7)(B)(ii) but not enough hours to
meet the more-than-half-the-personal-service requirement of
section 469(c)(7)(B)(i)).4 We also note that some of the
services which he asserts that he performed as to the rental
properties (e.g., his time dedicated to purchasing his residence
in Waltham, traveling between Vienna and Waltham outside of his
work for GTE, and assisting in the preparation of his personal
income tax returns) were for personal business, rather than
related to his rental activities, and that the logs, when
considered in connection with his time cards at GTE, reveal that
he claims to have worked almost 24 hours in a day and, on one
occasion, even more than 24 hours. We also consider implausible
on this record his assertion that he worked for GTE only 1,832
hours a year and that he spent almost all of his remaining time
working on his rental properties. See, e.g., Pohoski v.
Commissioner, T.C. Memo. 1998-17.
Because petitioner has failed to prove either of the
requirements set forth in section 469(c)(7)(B) for 1994 or 1995,
we hold for respondent. We have considered each of the arguments
4 In fact, petitioner increased in the current 1994 log the
number of hours in certain days he claimed to have worked on the
rental properties by as much as 10 to 15.5 hours from the
corresponding days listed in the prior log.
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