Carlton H. Perry - Page 11

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          log establishes that petitioner used the motor home to take trips           
          that were for the purpose of personal pleasure and recreation and           
          that were not related to petitioner's rental real estate activi-            
          ties.                                                                       
               The third document on which petitioner relies is entitled              
          "1989 Pace Summary of R.E [sic] Investment/Travel Activity" (real           
          estate log).  We have serious reservations about the reliability            
          of that document.  It purports to be a list of the real proper-             
          ties that petitioner allegedly visited during the trips in 1989             
          that he and Ms. Perry took in the motor home.  The real estate              
          log was created by petitioner on his personal computer and was              
          saved on a computer diskette.  Petitioner produced that log on              
          October 2, 1995, two days prior to the trial herein and after               
          having been informed by respondent's counsel that, as far as                
          respondent was concerned, the documents petitioner had presented            
          to respondent's counsel failed to establish a business purpose              
          for the motor home during 1989.  On cross-examination, when                 
          petitioner was asked whether he had made any substantive changes            
          to the real estate log prior to the trial, he was evasive in his            
          response.  In addition, the real estate log contained a general             
          and vague description of the real properties that petitioner                
          purportedly visited during 1989 and did not contain any specific            
          information relating to such properties, such as the addresses              

          6(...continued)                                                             
          determining whether the motor home was used in connection with              
          petitioner's rental real estate activities.                                 



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