William N. and Moira M. Carlstedt - Page 21

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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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