Richard B. May and Jane M. May - Page 5

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          he hires independent contractors for major repairs.  In addition,           
          he assists his tenants with various tasks, including completing             
          paperwork for those tenants receiving social services.                      
          Petitioner spends approximately 40-45 hours per week managing the           
          rental properties.                                                          
               In 1996, petitioners hired Joseph Mineo, a certified public            
          accountant, to prepare their 1993 return.  Mr. Mineo continued to           
          prepare petitioners’ returns for all relevant years.                        
               Petitioners attached to their 1993 return a Schedule E,                
          Supplemental Income and Loss, on which they aggregated                      
          petitioner’s rental income and expenses as if petitioner’s rental           
          real estate activities were a single activity.  Petitioners                 
          consistently followed this practice on the Schedules E attached             
          to their 1994, 1995, 1996, and 1997 returns.  Petitioners,                  
          however, did not attach to any of these returns a statement                 
          electing to treat petitioner’s rental real estate activities as a           
          single activity.                                                            
               On April 13, 1999, petitioners filed a joint Federal income            
          tax return for 1996.  On April 4, 2000, petitioners filed a joint           
          return for 1997.  Petitioners attached to each of these returns a           
          Schedule E on which they identified the rental real estate                  
          property as “Res Rental, Buffalo, NY” and claimed the following:            









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