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met with respect to this condominium activity. Petitioner failed
to show the Florida condo activity was conducted on a regular and
continuous basis during 1991 or that he was engaged in the
business of buying and selling real estate. McManus v.
Commissioner, supra. The majority of the actions taken by
petitioner with respect to the Florida condominium were, at best,
occasional and intermittent. The record indicates that, during
the year at issue, petitioner merely ran a series of
advertisements in the Washington Post offering the Florida
condominium for sale or lease. Petitioner and Mrs. Thompson
visited the condominium only twice during 1991, once to purchase
the property and once to meet with a potential purchaser or
lessee of the property. During their second visit, petitioner
and Mrs. Thomason stayed at the condominium and made minor
repairs to the condominium. Petitioner testified that he and
Mrs. Thomason spent a total of approximately 120 hours per week
on their various activities. However, no oral testimony or
documentary evidence was presented to show how much time they
actually spent on the Florida condo activity during 1991.
Furthermore, petitioner admitted that he and Mrs. Thomason spent
a majority of their time during 1991 on their rental real estate
activity (i.e., Maryland property).
On this record, the Court holds that petitioner has failed
to establish that, during 1991, he was engaged in the trade or
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