James V. and Judith M. Patterson - Page 4




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          maintenance services for the building, grounds, beachfront, and             
          pool.  A management service company known as the Kennedy Company            
          managed the rental unit during the years in issue.  The company             
          handled reservations, incoming and departing guests, and                    
          emergency repairs of the rental unit.  The company was also                 
          responsible for advertising the availability of the unit,                   
          negotiating leases, collecting lease payments, and providing                
          cleaning and repair services.  Petitioners paid the company 30              
          percent of rental income during 1994 and 25 percent of rental               
          income during 1996.  During 1996, the average rental period of              
          the unit was 5.6 days.  The unit was rented on the following                
          dates that year, with petitioners earning the specified amounts             
          of rental income and incurring the corresponding amounts of                 
          management fees:                                                            
                    Rental           Rental         Management                        
                    Period           Income           Fees                            
                    4/05-4/10           $360           $90.00                         
                    5/05-5/08            210            52.50                         
                    5/16-5/20            210            52.50                         
                    5/24-5/27            195            48.75                         
                    5/31-6/02            195            48.75                         
                    6/06-6/09            295            73.75                         
                    6/10-6/19            735           183.75                         
                    6/19-6/20            135            33.75                         
                    6/21-6/23            245            61.25                         
                    6/29-7/13          1,470           367.50                         
                    7/27-8/03            735           183.75                         
                    8/03-8/17          1,470           367.50                         
                    8/17-8/24            735           183.75                         
                    8/24-8/31            535           133.75                         
                    8/31-9/03            295            73.75                         
          The management service company paid several expenses on behalf of           
          petitioners during 1996.  The yearly income and expense statement           






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