- 2 - meaning of section 469.1 The case turns on whether the Lapids were “material participants” in their various real estate ventures. Background The Lapids were Michigan residents when they filed their petition. Mrs. Lapid is a cardiac nurse on the graveyard shift at a hospital in Troy, Michigan, and Mr. Lapid is a machinist at an engineering company there. They both work exceptionally long hours. Throughout 1999 and 2000, Mr. Lapid averaged between 9 to 10 hours a day and Mrs. Lapid worked 12 hours a night. Their work paid off, and they saved enough money to become investors. By 1999, the Lapids owned five condominiums in Florida. Four were units in two different condominium hotels near Orlando--a Day’s Inn and a Howard Johnson. Condominium hotels look like any other hotel. Guests check in, get a room, have full run of the hotel, and then check out. The hotels have people manning the front desk, and others working as housekeepers and janitors. The major difference between condominium and regular hotels is that each room in a condo hotel is owned by an investor who typically is not affiliated with the hotel’s management company. The brand name on the hotel (e.g., Day’s Inn, Howard Johnson), is the management company’s, not the 1 Section references are to the Internal Revenue Code of 1986, as amended.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011