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includes “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.” Id.
Petitioner contends that during taxable year 1998, he spent
more than 750 hours on his real estate activities and therefore
qualifies as a real estate professional under section 469(c)(7).
On his 1998 Form 1040, petitioner listed his occupation as a real
estate professional. At trial, petitioner stated that he paid a
management company to collect the rental payments from tenants
and pay some of the repair expenses pertaining to the rental
property. Petitioner further stated that the rental property was
“run down” and that he supervised the repair work performed on
the roof, pool, and landscape. Petitioner admitted that he
estimated the time he spent and did not keep a log of his time.
No appointment book, calendar, or narrative summaries were
submitted at trial.
We have only petitioner’s own oral testimony that he spent
the requisite number of hours on his real estate activities.
Petitioner failed to establish by any reasonable means that he
spent more than 750 hours on his real estate activities. Thus,
we must conclude that he was not a real estate professional under
section 469(c)(7)(B) during taxable year 1998.
Section 469(i) generally allows a $25,000 offset for rental
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