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program). Thus, according to petitioner, no one full-time
employee at Wisp could have participated more than petitioner.
To this effect, petitioner allocates all of her time spent on
board matters solely to her condominium. In contrast, petitioner
ratably allocates the time spent by employees running the day-to-
day operations of Wisp to all 167 units participating in the
rental program.
Petitioner suggests, and we accept, that all of her time
spent on board matters constitutes "participation" in the
condominium rental activity, without regard to any specific
connection of the board activities to petitioner's particular
unit. Petitioner also argues that the activities of Wisp
employees constitute "participation" for the purposes of section
1.469-5T(a)(3), Temporary Income Tax Regs., supra, only to the
extent that their services are directed towards petitioner's
specific unit. In this regard, there is nothing in the record
from which to calculate the precise amount of time spent by
employees in performing day-to-day services related solely to the
rental of petitioner's condominium. Likewise, there is no
evidence regarding the extent to which petitioner's activities as
a board member are specifically related to her unit. Given that
both petitioner and full-time staff, in their respective
capacities, served all Wisp units, we believe it reasonable to
assume that the portion of petitioner's board activities related
to the rental of her unit is commensurate with the portion of the
staff's activities related to the rental of petitioner's unit.
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