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It is apparent from petitioner's testimony, and the two
versions of the summary for 2000, that at best the summaries
represent estimates of the time devoted to the performance of
services associated with the condominium units. The Court will,
however, for purposes of discussion, accept as accurate the
summary for trial.
The Court views petitioners' summary for trial as describing
five categories of activity: (1) Responding to telephone and
Internet inquiries, and preparing and changing the Internet Web
site; (2) booking guests, confirming reservations, and arranging
for keys and parking passes; (3) travel by petitioners to and
from the property; (4) repair and cleaning of the property; and
(5) banking and bookkeeping.
Among excluded services are services similar to those
provided in connection with long-term rentals of high-grade
commercial or residential real property. Section 1.469-
1T(e)(3)(iv)(B), Temporary Income Tax Regs., 53 Fed. Reg. 5702
(Feb. 25, 1988). Petitioners allege that 150 hours were spent
responding to telephone and Internet inquiries to discuss the
amenities of the units, their availability, and their
desirability. An additional 64 hours are alleged to have been
spent preparing and changing the Web site at A1 Vacations, which
contained similar information. These activities can be fairly
described as marketing. Similar services are provided in
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