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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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