William C. and Cheryl M. Fowler - Page 5




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          Real Estate Rental Activities                                               
               Petitioners owned the following rental real estate                     
          properties:  (1) A farm and buildings in New York (New York                 
          property), (2) an apartment building in Pennsylvania (apartment             
          building), (3) a commercial building in Pennsylvania (commercial            
          building), and (4) a rental unit in Florida (Florida property).             
               Petitioner’s work on the rental properties included roofing            
          repair, electrical, heating system repairs, heating system                  
          replacement, foundation work, and routine maintenance.  Based on            
          petitioner’s calendar entries, petitioner prepared summaries of             
          the hours spent on each of the rental real estate activities.               
               In addition to the activities recorded in his calendar, he             
          computed an estimate of the hours spent traveling to and from the           
          rental properties and estimated the hours that he spent on                  
          administrative tasks.  Petitioner estimated that his travel time            
          from the Washington, D.C., area to Pennsylvania and New York was            
          about 7 hours each way and to Florida was about 21 hours each               
          way.  In 1994, petitioner made four trips to Florida and eight              
          trips to either New York or Pennsylvania.  In 1995, petitioner              
          made two trips to Florida and nine trips to either New York or              
          Pennsylvania.  Petitioner estimated that each year he spent                 
          approximately 80 to 100 hours on administrative work that related           
          to the rental activities.                                                   








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