Carlton H. Perry - Page 3

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               During the year at issue, petitioner, accompanied by his               
          then wife Ms. Perry, used the motor home for the purpose of                 
          taking trips to various locations in Oregon.  They used the motor           
          home to reach their destination, and they slept and ate in the              
          motor home during the course of those trips.  The trips that                
          petitioner and Ms. Perry took during 1989 were for the purpose of           
          personal pleasure and recreation and were not business related.             
          During 1989, petitioner did not at any time operate the motor               
          home as a rental property.                                                  
               During 1989, petitioner maintained a two-page handwritten              
          log, entitled "MILAGE [sic] RECORDS For 1989" (mileage log), in             
          which he recorded the following at the time he purchased gasoline           
          for the motor home:  The date of the purchase of gasoline, the              
          city in which it was purchased, the odometer reading of the motor           
          home, the generator use of the motor home, the number of gallons            
          of gasoline purchased, the dollar amount paid for the purchase of           
          gasoline, and other miscellaneous motor home expenses, such as              
          propane refills.  The mileage log did not in any way indicate               
          that there was any business purpose for the trips that petitioner           
          and Ms. Perry took in, or for any other use of, the motor home              
          during 1989.                                                                
               During 1989, petitioner also maintained a handwritten log              
          (handwritten log) consisting of 61 pages of notes that described            
          in detail the trips that he and Ms. Perry took in the motor home            
          during that year.  In that handwritten log, petitioner noted that           




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