Arnold P. Mordkin and Cindy Mordkin - Page 36

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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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