- 3 - 1994, to treat all interests in rental real estate as a single rental real estate activity pursuant to section 469(c)(7)(A). Petitioner kept daily calendars for 1996 and 1997 that contained various appointments related to her law practice and real estate activities. In preparation for trial, petitioner prepared a separate summary report of her calendars for 1996 and 1997. Each summary report provided an estimate of the total number of hours spent on activities related to each rental property and gave a general description of the activities performed by petitioner. The summary report also provided a general list of the legal activities performed by petitioner and estimated that she spent 876 hours in the practice of law in 1997. Indian Wells Properties Petitioner estimated that in 1997 she spent approximately 311 hours on activities related to the Indian Wells properties. Petitioner summarized her activities for 1997 as “re-rented, cleaned, did gardening, showed property to prospective renters, inspected repairmen’s work”. She also “started [the] process to sell by drawing up option[s] to purchase for prospective buyers [and] holding open houses.” Petitioner’s 1997 calendar indicates that she made 13 visits to the Indian Wells properties, 7 of which were in conjunction with matters relating to her law practice.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011