George and Bozenna Pohoski - Page 18

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          back or writing prospective tenants.  Additionally, it is likely            
          that petitioners received e-mail other than that relating to the            
          renting of their Hawaiian condominiums, and that such time was              
          included in the 225 hours allocated to checking the e-mail.                 
               Finally, we are mindful that petitioners were full-time                
          employees, each working 40 hours per week, and were the sole                
          managers of their Camarillo, California, condominiums.                      
               Using our best judgment, we find that petitioners spent                
          between 200 and 250 hours participating in the rental of their Maui         
          condo rather than the 325.5 hours proposed by petitioners.  We              
          further find that petitioners spent less  than  100  hours                  
          participating in the rental of their Molokai condo, rather than the         
          275.5 hours proposed by petitioners.  However, there still remains          
          the question of the amount of time spent by others working on the           
          rental of petitioners' condominiums.                                        
               We first consider the Maui condo.  Ms. Alders testified that           
          the front desk spent approximately 5 to 10 minutes checking in a            
          tenant for petitioners' Maui condo.  Mr. Pohoski estimated that the         
          maid service spent an average of 2 to 3 hours cleaning the Maui             
          condo after the departure of a tenant.  Ms. Alders opined that              
          petitioners "spent far more time" in operating the Maui condo than          
          Rainbow Reservations.  No testimony was presented with respect to           
          participation by other individuals at the Maui condo, nor was               
          testimony given with respect to the Molokai condo.                          





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