B. Theodore and Wendy Chapin - Page 8

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          such taxpayer should be permitted to use tax benefits from the              
          activity."  Id.                                                             
               It is important, therefore, to define the activity subject             
          to the limits of section 469.  For income tax purposes there are            
          generally two economic interests involved in the ownership of               
          real estate--the value of the asset as an investment, and if                
          rented, the value of the rental income.  As to the first, the               
          value of the asset may appreciate or depreciate, and, the                   
          resulting gain or loss is generally recognized as a capital                 
          transaction when the property is sold even though the economic              
          gain or loss was realized over the years that the property was              
          owned.  See sec. 1001.  On the other hand, the leasing activity             
          gives rise to gross income and deductions, and the net income or            
          loss generally is realized and recognized during each taxable               
          year that the property is rented.  See secs. 61, 441.  When                 
          section 469 applies to rental real estate, it operates to suspend           
          losses from the leasing activity.  Accordingly, we will use the             
          terms "activity" and "leasing activity" interchangeably.                    
               In this case, the average lease period of the condominium              
          was 7 days or less during the years at issue, and, therefore, the           
          leasing activity is not a "rental activity" for purposes of                 
          section 469(c)(2).  Sec. 1.469-1T(e)(3)(ii)(A), Temporary Income            
          Tax Regs., supra.  While the leasing activity falls outside the             
          definition of a "rental activity", section 469 nonetheless                  





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