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Office of Chief Counsel Internal Revenue Service Memorandum
www.irs.gova trade or business,1 a fully furnished vacation property via an online rental marketplace.2 The taxpayer is not a real estate dealer within the meaning of Treas. Reg. § 1.1402(a)-4(a).3 The taxpayer provides linens, kitchen utensils, and all other items to make the vacation property fully habitable for each occupant. In addition,