- 10 - 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-tripPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011