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Bluefin Bay consists of six buildings, each having a
different layout. The six buildings contain a total of 54
condominium units. Petitioners' unit is a three-bedroom unit.
As unit owners, petitioners were members of the Bluefin Bay
Condominium Association (BBCA), the common interest owner of
Bluefin Bay. Petitioner husband was one of BBCA's officers, at
one time serving as its president. BBCA owns all of Bluefin
Bay's common property, including an indoor swimming pool, tennis
courts, a conference room, a parking area, water and waste
treatment facilities, and communication and cable equipment.
BBCA arranged for the Tofte Management Company (TMC) to manage
and operate the Bluefin Bay complex. BBCA's members, the unit
owners, entered into individual management contracts with TMC.
The terms of the management contracts were the result of the
joint effort of numerous BBCA members, including petitioner
husband.
Petitioners' management contract with TMC was effective
January 1, 1991, through the taxable years in issue. Under the
management contract, TMC was appointed as the exclusive rental
agent for petitioners' unit. Petitioners were required to
specifically reserve their unit in writing for the days which
they intended to personally use it. In the event petitioners
failed to properly notify TMC of their intended use, rental
arrangements previously made by TMC with other guests would hold
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Last modified: May 25, 2011