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specializes in copying paintings that are displayed in the
National Gallery of Art in Washington, D.C. She does not
generally sell these reproductions.
During the years at issue, petitioners owned various rental
properties. In 1987, petitioners owned properties in Apopka,
Florida, and Silver Spring, Maryland. In 1988, petitioners
acquired another property in Silver Spring, Maryland. In 1989,
petitioners purchased property in Takoma Park, Maryland, and a
third property in Silver Spring, Maryland. These properties were
generally leased for 1 year terms.
Petitioners also own a condominium apartment (the
condominium) in Ocean City, Maryland. The condominium was
purchased in 1986 and consisted of two bedrooms, two full
bathrooms, a kitchen, a living room/dining room area, a
laundry/utility room, and a balcony. The condominium was rented
to tenants between June and September (the rental season). The
average rental term was 7 days or less for each of the years at
issue.
Petitioners left the day-to-day management of the property
in the hands of O'Conor, Piper & Flynn (the rental agent). The
rental agent's duties included advertising the property for rent,
receiving calls from prospective tenants, showing the condominium
to prospective tenants, dispensing and collecting keys,
collecting rent and deposits from tenants, hiring a cleaning
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