T.C. Memo. 1996-56 UNITED STATES TAX COURT B. THEODORE AND WENDY CHAPIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12106-94. Filed February 14, 1996. Ps own a beach condominium that is rented for an average period of 7 days or less during the June to September rental season. A rental agent handles all leasing arrangements, cleaning between tenants, and routine repairs and maintenance. Ps allege that they spend more than 170 hours during the nonrental season on cleaning and maintaining the condominium. Held: For purposes of sec. 469, I.R.C., Ps' participation in the activity does not constitute participation on a regular, continuous, and substantial basis. Accordingly, the losses incurred are subject to the passive loss rules of sec. 469, I.R.C. E. Gregory Lardieri and E. Newton Steely, Jr. (specially recognized), for petitioners. John C. Donovan, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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