Lucian T. Baldwin, III - Page 36

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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               
               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                   
               (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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