- 34 - concerned. The only person with resort management experience whom petitioner apparently consulted visited Granot Loma once and merely opined that the property might be used as a resort property without any apparent analysis of the pertinent financial data and without the benefit of any market study into the feasibility of operating such a resort profitably. Petitioner has conceded that Granot Loma was never operated as a commercial resort and that only invited guests stayed there during the years at issue. In testimony at trial, that concession was explained, at least in part, by the admission that petitioners did not want to open Granot Loma to uninvited guests because it would interfere with their use of the property. The evidence also suggests that, during the years at issue, LFI did not have the licenses and permits to operate a commercial facility required under Michigan State law, that Granot Loma was not insured for business use, and that LFI did not file State liquor tax returns or collect sales tax on its purported gross receipts. Although petitioner vociferously proclaimed throughout the trial that LFI operated Granot Loma for profit and was a real business, LFI did not take even the most minimal of steps under Michigan State law to make its alleged rental activity function like a real business. Petitioner argues that LFI made changes in its operation of Granot Loma to foster profitability. The principal change hePage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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