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During the years at issue, petitioner traveled from his home
in the St. Paul area to Hayward in a 1986 GMC van which he used
solely for trips to Hayward. When he was in Hayward, petitioner
ate and slept at the condominium. Petitioner's wife accompanied
him on 50 to 60 percent of his trips to Hayward. Some of the
time, petitioner's wife helped petitioner drive. While in
Hayward, petitioner's wife would use the condominium for her
personal activities, including reading, knitting, and
embroidering. Petitioner's wife would also shop in the Hayward
area. Sometimes petitioner's wife would play golf with
petitioner and other persons at the Tagalong Country Club near
Hayward and go out to dinner with petitioner and other persons in
Hayward. Petitioners maintained a boat which was located near
the Hayward condominium.
There were hotels, motels, and condominiums available for
rent in the Hayward area during the summers of 1987 and 1988.
Condominiums were rented in the Hayward area for approximately
$100 a day.
During the years at issue, the condominium was unsuitable
for use during the winter months.
During the years at issue, petitioners were members of and
paid dues to the Midland Hills Country Club of Roseville,
Minnesota (the country club). Both petitioners used the country
club. Both petitioners played golf at the country club.
Petitioner sometimes had meals and drinks at the country club
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