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priority over petitioners' personal use, unless the guests could
be assigned to another, comparable unit.
The management contract provided for TMC to receive 45
percent of the gross rental proceeds from petitioners' unit in
exchange for its services. Under the management contract, TMC's
duties included, but were not limited to, managing reservations,
checking in and out guests, providing housekeeping services,
collecting rents, generating financial reports, conducting damage
inspections, and making any necessary maintenance calls and
repairs.
TMC owns and operates a restaurant located adjacent to the
condominium complex. During the taxable years in issue, TMC's
employees staffed a reception desk near the restaurant entrance
for guests staying at Bluefin Bay. TMC also employed managers,
activity directors, bookkeepers, a housekeeping staff, and a
maintenance staff, all of whom participated in the activity of
renting petitioners' unit.
TMC's employees developed, drafted, and printed marketing
and promotional materials for Bluefin Bay. TMC maintained a
toll-free telephone number for promotional and reservation
purposes. TMC's employees answered this telephone line, booked
reservations for owners and guests, and mailed promotional and
marketing materials to interested parties.
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Last modified: May 25, 2011