Steven D. Rapp and Judith A. Rapp - Page 10




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          their hours of participation in the activity of renting their               
          unit, and petitioner husband's testimony.  Neither of the summary           
          documents was prepared contemporaneously.  Petitioner husband               
          testified that the detailed summary document (joint exhibit 6-F)            
          was prepared in 1994.  The other summary document was prepared at           
          some time after 1994 in preparation for this case and we do not             
          rely upon it.  We also have serious doubts about the accuracy of            
          the detailed summary document.  The monthly calendars corroborate           
          little more than the dates of petitioners' trips to Bluefin Bay             
          and petitioner husband's local BBCA meetings.  Petitioner                   
          husband's testimony establishes that he spent some hours working            
          out the details of the individual management contracts and                  
          serving as BBCA's president.  However, his testimony with respect           
          to petitioners' participation in renting the unit and performing            
          repairs to the unit was unpersuasive.  The maintenance records              
          show that petitioners filled out work orders for TMC's employees            
          to perform such simple repairs as replacing light bulbs.  In                
          addition, Dennis Rysdahl, who oversees the management and                   
          operation of Bluefin Bay and did so during the taxable years in             
          issue, testified that petitioner wife's participation in making             
          repairs and improvements to the unit was greater than petitioner            
          husband's.  Mr. Rysdahl testified that petitioner wife was                  
          involved in decorating the unit, but the maintenance records show           
          that petitioners left the actual work of decorating their unit to           






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