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tion, chairperson of the board of Crestwood Association, chair-
person of the executive committee, and chairperson of the manage-
ment compensation committee, petitioner spent time dealing with a
wide range of issues relating to the operations of Crestwood
Association. By way of illustration, petitioner dealt with
issues relating to the installation of the fire protection system
at Crestwood, the proposal by the town of Snowmass Village for
terminating its ownership of the Crestwood roads and parking
lots, employee housing, quality assurance, and management com-
pensation. The work done by petitioner in his capacity as a
board member and an officer of Crestwood Association was work he
did in the management of the operations of Crestwood Association
and was not the type of work that is considered investor par-
ticipation within the meaning of section 1.469-5T(f)(2)(ii)(B),
Temporary Income Tax Regs., supra.
The second preliminary issue we address is whether petition-
er's involvement as a board member and an officer in the opera-
tions of Crestwood Association constitutes participation by
petitioner in his rental activity at Crestwood within the meaning
of section 1.469-5(f)(1), Income Tax Regs. We note that, in
those capacities during the years at issue, petitioner dealt with
a wide range of issues that affected not only the two Crestwood
condominium units he owned, but also all other Crestwood condo-
minium units. At trial and on brief, petitioners assume, with no
discussion or explanation of the basis for such an assumption,
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