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connection with long-term rentals of high-grade commercial or
residential real property. Regardless of the hours spent, such
services are excluded services. Id.
Petitioner, or petitioner's agents, engaged in booking
guests, confirming reservations and security deposits, and
arranging for keys and parking passes, activities allegedly
requiring 45 hours. The services may have been performed more
frequently than at typical high-grade commercial or residential
real properties. Petitioners have, however, provided little
evidence as to whether the provided personal services were
significant, especially in terms of their value and the
relationship of that value to the amount charged for use of the
properties.
Some of the reservation services were provided by Advisors
for a 30-percent commission. But the same commission also paid
for accounting services, advertising and promotion, cleaning
equipment and supplies, an inspection prior to return of the
damage deposit, and an annual inspection and inventory. Some of
the services are excluded services. The Court is unable to
determine how to allocate the commission to the various services
provided. Petitioner provided no evidence of the value of the
reservation services that he performed. The Court concludes that
the reservation type services were not significant personal
services. The travel by petitioners, a 1,570 mile round-trip
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