- 9 - petitioner actually spent servicing his rental properties. Consequently, even if we were to give weight to the daily work log, that document by its own terms would not have established that petitioner spent more than one-half of his time engaged in rental real estate activities or that the time petitioner spent on such rental real estate activities amounts to more than 750 hours of service for purposes of section 469(c)(7)(B). Other evidence introduced by petitioners at trial was petitioner's letter to the Court, dated June 13, 2003, in which petitioner described his typical work schedule and petitioners’ oral testimony at trial. It is well established that the Court is not bound to accept at face value such uncorroborated and self-serving testimony from a taxpayer. Shea v. Commissioner, 112 T.C. 183, 189 (1999); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Petitioners did not provide appointment books, calendars, or narrative summaries describing in a detailed and convincing manner the hours that petitioner actually spent engaged in his real property activity and did not call any corroborating witnesses to substantiate their own testimony. In light of his full work schedule at the Dial Corporation, petitioner would have to provide substantial and detailed evidence to convince us that he managed to spend more than one- half of his time on rental real estate activities or that he even spent more than 750 hours on them during the year in issue. WePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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