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but include “the 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.; see Mowafi v.
Commissioner, T.C. Memo. 2001-111. But despite its apparent
leniency, this section of the regulations does not require us to
believe a “ballpark guesstimate” of the time spent on different
activities. Carlstedt v. Commissioner, T.C. Memo. 1997-331;
Speer v. Commissioner, T.C. Memo. 1996-323; Goshorn v.
Commissioner, T.C. Memo. 1993-578.
The Lees tried to prove their cases with time logs. These
were not contemporaneous logs, though, but reconstructions based
on each brother’s personal experience and a smattering of the
partnership’s records from 1999 and 2000. According to the Lees,
they worked enormously long hours on their real estate business.
Kai claimed to rack up 2,087 hours in 1999 and 2,226 hours in
2000. And Ulysses worked only a little less--reporting on his
logs that he spent 2,063 hours in 1999 and 2,102 hours in 2000,
working with his brother on these small properties.
We do not find these logs, or the testimony accompanying
them, credible. The credibility problems begin with the fact,
which we already noted, that both brothers had full-time salaried
jobs during 1999 and 2000--Kai as a professor of radiology, and
Ulysses as an IRS examiner. Kai also worked for his own
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