- 10 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011