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she spent on the rental activities. Petitioners did produce a
number of documents, however, including more than 400 pages of
e-mail messages sent to and from an e-mail account they
maintained for the rental activities, sales and marketing
materials they developed, a “cost analysis” and “cash flow
analysis” they prepared, and various other documents relating to
the rental activities such as photographs, worksheets,
handwritten notes, receipts, and correspondence.
Petitioners also produced two summaries of the time spent on
the rental activities. The first summary is titled “Susan
Hanna’s Activity for Year 2000” and indicates that Mrs. Hanna
spent 3,247 hours on rental activities. This document does not
indicate when it was prepared. The second document is an 89-page
“narrative summary” of each petitioner’s rental activities that
they created shortly before trial. This document indicates that
Mrs. Hanna spent 2,610 hours on rental activities in 2000.
Petitioners did not explain the discrepancy between the two
summaries. Petitioners’ pretrial memorandum lists the 2,610-hour
figure, however, and petitioners consistently used that figure at
trial. Furthermore, petitioners made frequent reference to the
89-page narrative summary during their testimony. Accordingly,
we assume that petitioners’ position is that Mrs. Hanna worked
2,610 hours on rental activities in 2000. The narrative summary
provides the following breakdown of those hours:
Category Hours
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Last modified: May 25, 2011