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alleged business activities is inadequate, ambiguous, and
unconvincing. For example, although petitioner and his family
made several visits to Granot Loma during the renovation period,
petitioner kept no log or other records of the actual time he
spent on the renovation effort. Moreover, even if we were
willing to accept petitioner’s undocumented claims of time spent
on the renovation effort, petitioner’s involvement with and
“supervision” of the renovation was completely consistent with
the desire of any homeowner to make informed decisions regarding
the nature and manner of the work to be done and to monitor the
renovation on his home. The ambiguous nature of petitioner’s
testimony renders petitioner’s testimony unconvincing and not
credible.
Respondent presented a much more compelling picture of the
“reality” of Granot Loma. In addition to the regular use of
Granot Loma by petitioner and his family, friends, and business
acquaintances, respondent introduced evidence showing the
following:
(1) Petitioner’s accountant “conservatively” concluded that
the vast majority of visits paid for by petitioner’s companies
were for petitioners’ personal use of Granot Loma;
(2) during the years at issue, petitioner was a man of
considerable financial means who earned millions of dollar each
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