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Robert Serenbetz is a business executive. During the years
under consideration, he was the president and chief operating
officer of DNA Plant Technology Corporation, an agricultural
biotechnology company. Prior thereto, he was a vice president of
Warner-Lambert Co. and the president of American Chicle. Mrs.
Serenbetz is a homemaker.
During the years under consideration, petitioners owned a
condominium in Notch Brook Resort Condominiums, a 50-unit
development located in Stowe, Vermont (the Vermont condominium).
All condominium owners were members of the condominium association,
and those condominium owners who wished to rent their units to
third parties were partners in the Notch Brook Hotel Condominium
Partnership (the partnership). Petitioners were members of the
partnership, as were about 40 other owners.
The condominium association was governed by a board of
directors. Mr. Serenbetz was a member of the board of directors of
the condominium association in both 1991 and 1992. That board met
on a regular basis, and Mr. Serenbetz sometimes participated in
meetings by telephone. In 1991, Mr. Serenbetz spent 36 hours
preparing for and attending meetings, reviewing minutes of
meetings, and discussing the meetings with his wife. Mr. Serenbetz
spent 22 hours in 1992 preparing for and attending board meetings
and reviewing minutes of the board meetings.
The day-to-day rental operation of the partnership was run and
managed by an on-site staff of nine employees of both the
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