Carlton H. Perry - Page 10

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          mileage log and the handwritten log.  The mileage log contained             
          information relating to the dates on which petitioner purchased             
          gasoline for the motor home, the cities in which it was pur-                
          chased, the odometer readings of the motor home, the generator              
          use of the motor home, the number of gallons of gasoline pur-               
          chased, the respective dollar amounts paid for the gasoline                 
          purchased, and other miscellaneous motor home expenses, such as             
          propane refills.  The handwritten log consisted of 61 pages of              
          notes in which petitioner described in detail his experiences               
          during the trips that he and Ms. Perry took in the motor home               
          during the months of April through October 1989, including the              
          places at which they camped, the walks and hikes they took, the             
          flowers, plants, and wildlife they saw, an old grave site they              
          visited, the sunrises and the sunsets they watched, and the food            
          they ate.  Neither the mileage log nor the handwritten log in any           
          way indicated 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 1989.6  To the contrary, the handwritten              

          6  Petitioner testified that notations made in the far right                
          margin of the mileage log in the form of slash marks under a                
          column labeled "Calls" represent the times that he met with his             
          tenants in the motor home with respect to matters relating to his           
          real estate rentals.  Petitioner further testified inconsistently           
          as to whether those notations were contemporaneous records of               
          those alleged meetings.  The mileage log contained no notations             
          of (1) the names of the tenants with whom petitioner allegedly              
          met in the motor home, (2) the dates or the times of such alleged           
          meetings, or (3) the subjects that he discussed during such                 
          alleged meetings.  On the instant record, we place no particular            
          weight on the slash marks in the mileage log or, for the reasons            
          stated above, on petitioner's testimony concerning them in                  
                                                             (continued...)           


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