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their hours of participation in the activity of renting their
unit, and petitioner husband's testimony. Neither of the summary
documents was prepared contemporaneously. Petitioner husband
testified that the detailed summary document (joint exhibit 6-F)
was prepared in 1994. The other summary document was prepared at
some time after 1994 in preparation for this case and we do not
rely upon it. We also have serious doubts about the accuracy of
the detailed summary document. The monthly calendars corroborate
little more than the dates of petitioners' trips to Bluefin Bay
and petitioner husband's local BBCA meetings. Petitioner
husband's testimony establishes that he spent some hours working
out the details of the individual management contracts and
serving as BBCA's president. However, his testimony with respect
to petitioners' participation in renting the unit and performing
repairs to the unit was unpersuasive. The maintenance records
show that petitioners filled out work orders for TMC's employees
to perform such simple repairs as replacing light bulbs. In
addition, Dennis Rysdahl, who oversees the management and
operation of Bluefin Bay and did so during the taxable years in
issue, testified that petitioner wife's participation in making
repairs and improvements to the unit was greater than petitioner
husband's. Mr. Rysdahl testified that petitioner wife was
involved in decorating the unit, but the maintenance records show
that petitioners left the actual work of decorating their unit to
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