Edward C. and Susan R. Hanna - Page 4

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          operated their rental activities from their home in Weston,                 
          Massachusetts.  Petitioners received on-site assistance from                
          George Veillette, a Sanibel resident and real estate agent who              
          sold petitioners their first two rental properties.  Mr.                    
          Veillette periodically checked the properties when they were                
          vacant to make sure the premises were secure, and the water and             
          heat systems were functioning.  He also supplied keys to                    
          repairmen and, on rare occasions, to renters.  Mr. Veillette                
          estimated he spent a total of approximately 6 hours a month                 
          looking after the properties.                                               
               Although petitioners both spent time on the rental                     
          activities, Mrs. Hanna performed the majority of the work.  She             
          designed and constructed one or more Internet Web sites to help             
          advertise the properties, designed and placed advertisements in             
          newspapers, responded to e-mails from prospective customers, and            
          performed a number of other tasks.  Petitioners traveled to                 
          Florida five times in 2000, spending a total of approximately 5             
          weeks there.  During their visits petitioners looked for                    
          additional properties to buy, met potential customers, and                  
          arranged for cleaning, maintenance, and repairs for their                   
          existing properties.                                                        
               In addition to managing their rental activities in 2000,               
          both petitioners worked full time in the Boston, Massachusetts,             
          metropolitan area.  Mr. Hanna worked as a project manager for               
          Fidelity Investments, earning a salary of $125,371 for                      

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