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petitioners had trouble getting some of the renters out of their
property.
Starting around 1994, after the short-term lessees were
removed, petitioners began entering into longer term leases with
multiple occupants without using the vacation property management
companies. But even the longer term renters caused a lot of
"trouble", including leaving mattresses outdoors in the carport,
and building a skate ramp in the back of the property in
contravention of the homeowners' association rules. Petitioners
eventually decided that they were "only going to rent to people
that we knew, or were acquaintances, or people we worked with."
During 1999 and 2000, petitioners relied on word of mouth
advertising at work to obtain renters. Petitioners' books and
records for their rental activity consisted of calendars, logs of
their mileage driven, retained utility and insurance bills, and
bills for association dues. During 1999, petitioners rented the
property in Truckee for 25-1/2 days and stayed there themselves
for 8 days. During 2000, petitioners rented the property for 23
days and stayed there for 8 days. Petitioners reported rents
received of $1,400 for 1999 and $1,500 for 2000, and Schedule E
losses of $19,322 for 1999 and $19,336 for 2000.
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