Arnold P. Mordkin and Cindy Mordkin - Page 3

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          professional corporation also located in California.  During                
          those years, petitioner's legal practice was his primary source             
          of income.                                                                  
          Crestwood Condominiums                                                      
               In March 1982 and October 1985, petitioner purchased unit              
          no. 2303 and unit no. 2301, respectively, at a condominium                  
          development known as Crestwood Condominiums (Crestwood) that is             
          located in Snowmass Village, Colorado (Snowmass Village).  During           
          the years at issue, Crestwood had 141 condominium units that were           
          owned by various persons.                                                   
               During all relevant periods, Crestwood Condominium Associa-            
          tion, Inc. (Crestwood Association), a membership association                
          whose members consisted of all the Crestwood condominium owners,            
          was responsible for the operations at Crestwood.  During those              
          periods, Crestwood Association had a nine-member board of direc-            
          tors (board) that was elected by the members of that association            
          and that oversaw, and made policy regarding, its operations.                
               During all relevant periods, Crestwood Association ran two             
          separate and distinct operations:  (1) Those operations affecting           
          all Crestwood condominium owners that involved providing services           
          to, and fulfilling the obligations of, those owners, including              
          maintaining and repairing Crestwood's common areas and building             
          structures and obtaining, as required, casualty, public liability           
          and property damage, workmen's compensation and employer's                  
          liability insurance as well as other types of insurance that                

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