- 21 - We think that, in general, petitioner has attempted to give credible testimony as to the services he performed for CDI during the relevant period. Under the circumstances, however, we believe that the methods petitioner used to approximate the time he spent performing such services during 1990 and 1991 are not reasonable within the meaning of section 1.469-5T(f)(4), Temporary Income Tax Regs. This Court has previously noted that, while the regulations are somewhat ambivalent concerning the records to be maintained by taxpayers, they by no means allow a postevent "ballpark guesstimate". Speer v. Commissioner, T.C. Memo. 1996-323 (quoting Goshorn v. Commissioner, T.C. Memo. 1993-578). In the instant case, while perhaps not falling within the postevent "ballpark guesstimate" category, Goshorn v. Commissioner, supra, we nevertheless conclude that petitioner's estimates were, on the whole, unreliable and inconsistent. Petitioner's rationale for allegedly spending less than 500 hours per year on CDI activities, as well as the testimony of petitioners' witnesses, fails to convince us otherwise. In response to petitioners' concerns, we do not question the fact that petitioner's various enterprises were separate legalPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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