- 8 - decided on the 10-hour figure because “she knew she had all day to do it” and because Home Depot opened at 7 o’clock. We do not find petitioners’ calendar or summary to be persuasive. See Wichita Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947). The summarization in particular appears to be more akin to the unacceptable ballpark guesstimates we have rejected in the past than it is to “reasonable means” that would establish that Mrs. Harmon actually spent 774.5 hours on real estate activities in 2001. 2. More than one-half of the personal services performed in trades or businesses by the taxpayer Assuming, arguendo, that we were persuaded by petitioners’ claim that Mrs. Harmon spent 774.5 hours on real estate activities in 2001, petitioners are still unable to satisfy the other portion of the test outlined in section 469(c)(7)(B) for treatment as a real estate professional. According to section 469(c)(7)(B)(i), petitioners have to prove that more than one-half of Mrs. Harmon’s personal services performed in trades or businesses in 2001 were performed in real property trades or businesses. Petitioners are unable to do so. Petitioners argue that Mrs. Harmon’s other personal service commitments were sufficiently minimal so as to permit the 774.5 hours she claims to have spent on rental activities to constitute more than one-half of the personal services she performed inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007