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which he prepared in connection with his audit to support the
hours of personal time which he purportedly devoted to the rental
properties. The logs list 2,102.5 hours and 2,116.5 hours of
personal time that petitioner spent during the respective years
working on the rental properties. We find these logs
untrustworthy and decline to rely blindly upon them to reach
petitioner’s desired result.3 Cf. Rapp v. Commissioner, T.C.
Memo. 1999-249. Petitioner, for example, prepared these logs 2
to 3 years after the fact admittedly on the basis of speculation
and with an end result in mind (i.e., the need to arrive at a
certain minimum number of hours being attributable to the rental
properties so that he would meet both the more-than-half-the-
personal-service requirement of section 469(c)(7)(B)(i) and the
750-hour requirement of section 469(c)(7)(B)(ii)), and he
concedes that the times set forth therein may be off by as much
as 20 percent. The 1994 log also conflicts dramatically with an
earlier log that he prepared listing the time that he purportedly
spent on the rental properties; the prior log lists 1,096.5 hours
of personal services that he performed as to the rental
3 As to petitioner’s testimony, we find much of it to be
improbable, questionable, uncorroborated, inconsistent, and self-
serving. Under the circumstances, we are not required to, and we
do not, rely on that testimony to support his position herein.
See Cebollero v. Commissioner, 967 F.2d 986, 989 (4th Cir. 1992),
affg. T.C. Memo. 1990-618; Gatling v. Commissioner, 286 F.2d 139,
143-144 (4th Cir. 1961), affg. T.C. Memo. 1959-224; Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986).
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