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1994, to treat all interests in rental real estate as a single
rental real estate activity pursuant to section 469(c)(7)(A).
Petitioner kept daily calendars for 1996 and 1997 that
contained various appointments related to her law practice and
real estate activities. In preparation for trial, petitioner
prepared a separate summary report of her calendars for 1996 and
1997. Each summary report provided an estimate of the total
number of hours spent on activities related to each rental
property and gave a general description of the activities
performed by petitioner. The summary report also provided a
general list of the legal activities performed by petitioner and
estimated that she spent 876 hours in the practice of law in
1997.
Indian Wells Properties
Petitioner estimated that in 1997 she spent approximately
311 hours on activities related to the Indian Wells properties.
Petitioner summarized her activities for 1997 as “re-rented,
cleaned, did gardening, showed property to prospective renters,
inspected repairmen’s work”. She also “started [the] process to
sell by drawing up option[s] to purchase for prospective buyers
[and] holding open houses.” Petitioner’s 1997 calendar indicates
that she made 13 visits to the Indian Wells properties, 7 of
which were in conjunction with matters relating to her law
practice.
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