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material participation in the operation of the hotel
room rental business. [132 Cong. Rec. 15032 (1986).]
The foregoing colloquy between Senator Hatfield and Senator
Packwood makes it clear that services performed by a taxpayer
that are deemed integral to the operations of a condominium hotel
will constitute material participation by the taxpayer in those
operations only if the taxpayer performs those services in such a
way and "to such an extent" that it shows that the taxpayer's
involvement in those operations is regular, continuous, and
substantial. Id. Contrary to petitioner's contention, that
colloquy does not in any way suggest that, in determining whether
a taxpayer's participation in the operations of an activity is
material, it is unreasonable to examine the amount and extent of
time spent by the taxpayer in those operations.
Indeed, a review of other portions of the legislative his-
tory of section 469 confirms that the material participation test
implicates the amount and extent of the time spent by a taxpayer
in connection with the operations of an activity. For instance,
that legislative history indicates that a taxpayer is most likely
to participate materially in an activity if involvement in that
activity is the taxpayer's principal business and the taxpayer
devotes most of his or her time to that business and does not
devote a comparable amount of time to another business (principal
business factor). S. Rept. 99-313 (1986), 1986-3 C.B. (Vol. 3)
713, 732-733. The legislative history of section 469 also indi-
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