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guests departed. The cleaning activity included cleaning the
interior of the unit and laundering the linens and towels.
TMC's employees maintained daily books and records
reflecting the collected rents and fees owed by petitioners.
They issued monthly and annual reports to petitioners reflecting
the rental activity, owner charges, and TMC's share of the gross
rentals.
Petitioners' duties under the management contract included
providing TMC with a schedule of their intended personal use,
maintaining adequate insurance on their unit, and complying with
certain "Interior Quality Standards".
TMC made detailed inspections of petitioners' unit at least
annually and compiled lists of mandatory repairs and items which
needed to be replaced in order to satisfy the Interior Quality
Standards. Petitioners were given the choice to personally make
these repairs and improvements or to authorize TMC to make them.
If they failed to comply by certain dates, TMC would arrange for
the work to be performed by its employees or subcontractors and
charge petitioners accordingly.
Petitioners traveled to Bluefin Bay 5 or 6 times during each
of the taxable years. In most cases, petitioners would stay at
Bluefin Bay in their unit for a long weekend. They also spent 1
full week each summer in their unit. Petitioners' trips to
Bluefin Bay usually combined family vacations with owner
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Last modified: May 25, 2011