Robert Serenbetz and Karen J. Serenbetz - Page 4

          partnership and the condominium association.  The employees include                
          a  manager, assistant manager, bookkeeper, front-desk staff person,                
          housekeepers, and maintenance staff.  The employees maintained the                 
          partnership books and records, maintained the units and grounds,                   
          and marketed and advertised the rental operation.  The partnership                 
          pays for the property insurance, utilities, and repairs of the                     
          units owned by its partners.                                                       
                The expenses from all of the partners' units were pooled and                 
          shared ratably among the  partners  based  on  the  partner's                      
          partnership interest (which was based on his interest in the                       
          condominium association) and the number of days each unit was                      
          available for rent during the year.  Petitioners shared in                         
          partnership rental income for each day their unit was available for                
          rent, even if it was not actually rented.                                          
                Under the partnership agreement, each unit owner is entitled                 
          to use his unit without charge for no more than 4 weeks during the                 
          winter season and 4 weeks during the summer season.  Should the                    
          unit owner occupy his unit more than his/her allotted time, he is                  
          charged 50 percent of the established regular seasonal hotel rate.                 
          There is no limitation on the owner's occupancy during the other                   
          periods of the year.  Petitioners and/or their children used their                 
          condominium less than 10 days during each year under consideration.                
                For the years under consideration, petitioners reported the                  
          income and expenses of their Vermont condominium as a trade or                     
          business activity on Schedule C of their tax return.  In 1991, they                

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