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1.469-5T(f)(4), Temporary Income Tax Regs., 53 Fed. Reg. 5727 (Feb.
25, 1988). That regulation provides as follows:
The extent of an individual's participation in an
activity may be established by any reasonable means.
Contemporaneous daily time reports, logs, or similar
documents are not required if the extent of such
participation may be established by other reasonable
means. Reasonable means for purposes of this paragraph
may include but are not limited to the identification of
services performed over a period of time and the
approximate number of hours spent performing such
services during such period, based on appointment books,
calendars, or narrative summaries.
At trial, petitioners introduced a narrative summary of their
rental activities with respect to their participation in the
Hawaiian condominiums in the form of a letter, dated October 17,
1996, to Ms. Ingrid Giammichele, an Internal Revenue Service (IRS)
Appeals officer in California. The narrative summary details the
expenses, time, and effort put forth by petitioners in operating
their Hawaiian condominiums. Respondent claims, however, that the
narrative summary is merely a postevent "ballpark guesstimate" that
is insufficient to prove participation. See Carlstedt v.
Commissioner, T.C. Memo. 1997-331; Speer v. Commissioner, T.C.
Memo. 1996-323; Goshorn v. Commissioner, T.C. Memo. 1993-578.
Although petitioners' narrative summary is a postevent review
of their 1993 participation with respect to the Hawaiian
condominiums, we may nonetheless find the summary sufficient to
establish petitioners' participation where it is supported by
credible testimony and other objective evidence. See Harrison v.
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