Robert P. Sweet and Dawnielle K. Lawson - Page 14

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          to place enough emphasis on the "making the property available              
          for use by customers" language qualifying "in connection with."             
               Legislative history of section 469 suggests that "section              
          1372(e)(5) (as in effect prior to the Subchapter S Revision Act             
          of 1982) is relevant" in determining whether significant services           
          are performed in connection with furnishing property.  S. Rept.             
          99-313 at 741 n.32 (1986).  The regulations provided that,                  
          generally, only services provided to the occupant "primarily for            
          his convenience" are to be considered significant services.                 
          Stover v. Commissioner, 781 F.2d 137, 139 (8th Cir. 1986), affg.            
          T.C. Memo. 1984-551; Bramlette Bldg. Corp. v. Commissioner, 52              
          T.C. 200, 203-204 (1969), affd. 424 F.2d 751 (5th Cir. 1970).               
          Petitioners' attendance at owners association meetings and their            
          banking activities have more to do with the ownership of property           
          than with making the properties available to customers.  The                
          activities are not significant personal services.                           
               Petitioners have also alleged that they incurred higher than           
          normal owners association charges, dues, and assessments for                
          additional amenities such as beach chair rentals, bars, a game              
          room and a parking lot.  Nearly all the services listed are of a            
          type commonly rendered by luxury apartment complexes, especially            
          on the Florida Coast.  See Crouch v. United States, 692 F.2d 97,            
          101 (10th Cir. 1982).                                                       








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