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inspections, and making any necessary maintenance calls and
repairs.
TMC owns and operates a restaurant located adjacent to the
condominium complex. During the taxable years in issue, TMC's
employees staffed a reception desk near the restaurant entrance
for guests staying at Bluefin Bay. TMC also employed managers,
activity directors, bookkeepers, a housekeeping staff, and a
maintenance staff, all of whom participated in the activity of
renting petitioners' unit.
TMC's employees developed, drafted, and printed marketing
and promotional materials for Bluefin Bay. TMC maintained a
toll-free telephone number for promotional and reservation
purposes. TMC's employees answered this telephone line, booked
reservations for owners and guests, and mailed promotional and
marketing materials to interested parties.
TMC's employees checked in guests, received deposits, and
issued keys. They responded to maintenance calls and made any
necessary repairs. TMC's employees opened, closed, and cleaned
the pool, hot tub, and pool house on a daily basis. They also
maintained Bluefin Bay's tennis courts and exercise room. In the
winters, TMC's employees plowed the parking lots and shoveled,
salted, and sanded the walkways.
TMC's employees collected payments from guests and checked
them out of the unit. They cleaned and inspected the unit after
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Last modified: May 25, 2011