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activities. Petitioner attempted to summarize the activities
that were noted in her 1997 calendar into a summary report, in
which she generally explained the activities performed at the
rental properties and provided an annual estimate of the hours
spent on each rental property. Excluding petitioner’s estimate
of the hours that she spent on activities directly related to the
Lake Arrowhead property, petitioner’s summary report estimated
that she spent 827 hours performing services related to the
rental properties during 1997 and consisted of the following:
(1) Indian Wells properties, 311 hours; (2) Elderwood properties,
412 hours; and (3) general activities for all real estate
properties (including the Lake Arrowhead property), 104 hours.
We believe that the methods that petitioner used to approximate
the time that she spent performing these services during 1997 are
not reasonable within the meaning of section 1.469-5T(f)(4),
Temporary Income Tax Regs., supra. Petitioner’s estimates are
uncorroborated and do not reliably reflect the hours that she
devoted to her rental real estate activities. Petitioner
assigned hours to activities years later, and in preparation for
trial, based solely on her judgment and experience as to how much
time the activities must have taken her. This Court has
previously noted that, while the regulations are somewhat
ambivalent concerning the records to be maintained by taxpayers,
they do not allow a postevent “ballpark guesstimate”. Carlstedt
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