James V. and Judith M. Patterson - Page 8




                                        - 7 -                                         
          Thus, we need not address whether the participation of other                
          individuals was greater than that of petitioners.                           
               We sustain respondent’s determination that the rental of the           
          condominium was a passive activity subject to the limitations of            
          section 469.                                                                
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               































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