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Petitioner argues that her participation in Scheiner &
Halpern constitutes a significant participation activity.10
Petitioner's testimony with regard to the time spent working for
Scheiner & Halpern, however, is not corroborated by written
documentation. The regulations specify that participation in an
activity may be established by any reasonable means. While
contemporaneous records are not required, reasonable means may
include appointment books, calendars, or narrative summaries.
Sec. 1.469-5T(f)(4), Temporary Income Tax Regs., supra.
Given the self-serving nature of petitioner's testimony,
coupled with the lack of corroboration in the record, we do not
accept her naked assertion that she worked the requisite amount
of hours to qualify her accounting partnership activity as a
significant participation activity. We are particularly troubled
with petitioner's ability to recall, without any records, the
number of hours of participation in her accounting partnership
which neatly places her over all of the hurdles necessary to
satisfy the requirements of section 1.469-5T(a)(4), Temporary
Income Tax Regs., supra. The record indicates that in other
aspects of her activities, petitioner maintained thorough
documentation, as would be expected of someone in her profession.
10 Petitioner testified that she worked 426 hours for
Scheiner and Halpern in 1991 and 402 hours in 1992, while her
partner worked 469 hours in 1991 and 440 hours in 1992. Were we
to accept petitioner's testimony, her activity at Scheiner and
Halpern would constitute a significant participation activity
which, when added to the time spent at Wisp, might exceed 500
hours.
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