Robert P. Sweet and Dawnielle K. Lawson - Page 5

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          cleaning charge paid for Advisors' housekeeping or "maid service"           
          following rental departures, which in petitioner's case would               
          have included cleaning and linen exchange.  Petitioner provided             
          the maid and linen service at no "extra" charge to customers.               
          Each owner, however, was free to book his own guests or allow               
          Advisors to do it for commission.  Petitioner periodically                  
          allowed Advisors to book guests for his units and paid the                  
          standard commission.                                                        
               Petitioner sought to minimize the involvement of Advisors,             
          and avoid their commission, by executing his own marketing                  
          activity and customer bookings.  In 2000, petitioner put together           
          and maintained a Web page that advertised units 518 and 519.  He            
          created the Web site by entering contact information and                    
          information about the amenities offered by his condominium into a           
          "template" on a preexisting site called A1 Vacations.                       
          Petitioners received gross rental income of $29,467 during 2000,            
          of which $11,137 was received through bookings from Advisors.               
               Petitioners required their guests to call them before                  
          contacting the front desk with problems and concerns as a way to            
          avoid high fees charged by the owners association for routine               
          maintenance items like changing light bulbs.  Petitioners also              
          led guests that they booked through a detailed telephone check-in           
          procedure.  Petitioners maintained a storage area onsite                    
          containing certain replacement items.                                       






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