George and Bozenna Pohoski - Page 3

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          1. Hawaiian Condominiums                                                    
               In 1991, petitioners purchased a condominium at the Valley             
          Isle Resort on the island of Maui, Hawaii (the Maui condo).  In             
          1992, petitioners purchased a condominium at the Wavecrest Resort           
          on the island of Molokai, Hawaii (the Molokai condo).  Both of              
          these condominiums were purchased as rentals to vacationers.  Each          
          condominium included one bedroom, one bathroom, a living room,              
          kitchen, dining room, and lanai.1                                           
               A. Maui Condo                                                          
               As owners of the Maui condo, petitioners were members of the           
          Homeowners' Association at the Valley Isle Resort (Homeowners'              
          Association).  The Homeowners' Association entered into a contract          
          with Rainbow Reservations, Inc. (Rainbow Reservations) to operate           
          the front desk for the Valley Isle Resort condominiums.  Rainbow            
          Reservations also provided management services for individual               
          condominium owners.  During 1993, Rainbow Reservations entered into         
          management contracts with owners of approximately 40 of the 120             
          condominium units at the Valley Isle Resort.                                
               Generally, Rainbow Reservations provided a variety of services         
          for the condominium owners with whom they had management contracts,         
          including the rental of the condominium units, collection of rents,         
          after-hours front desk services, maid services, repair and                  
          maintenance services, and redecorating services.    Rainbow                 


               1    A lanai is a Hawaiian term for a porch or veranda.                



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