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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 legal
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