Robert P. Sweet and Dawnielle K. Lawson - Page 11

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          connection with long-term rentals of high-grade commercial or               
          residential real property.  Regardless of the hours spent, such             
          services are excluded services.  Id.                                        
               Petitioner, or petitioner's agents, engaged in booking                 
          guests, confirming reservations and security deposits, and                  
          arranging for keys and parking passes, activities allegedly                 
          requiring 45 hours.  The services may have been performed more              
          frequently than at typical high-grade commercial or residential             
          real properties.  Petitioners have, however, provided little                
          evidence as to whether the provided personal services were                  
          significant, especially in terms of their value and the                     
          relationship of that value to the amount charged for use of the             
          properties.                                                                 
               Some of the reservation services were provided by Advisors             
          for a 30-percent commission.  But the same commission also paid             
          for accounting services, advertising and promotion, cleaning                
          equipment and supplies, an inspection prior to return of the                
          damage deposit, and an annual inspection and inventory.  Some of            
          the services are excluded services.  The Court is unable to                 
          determine how to allocate the commission to the various services            
          provided.  Petitioner provided no evidence of the value of the              
          reservation services that he performed.  The Court concludes that           
          the reservation type services were not significant personal                 
          services. The travel by petitioners, a 1,570 mile round-trip                






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