Andre and Vena Nelson - Page 10

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          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.  We             






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