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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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