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(A) regular,
(B) continuous, and
(C) substantial.
In determining whether a taxpayer materially participated in an
activity, the participation of the spouse of a taxpayer in the
activity is also taken into account. Sec. 469(h)(5); sec. 1.469-
5T(f)(3), Temporary Income Tax Regs., 53 Fed. Reg. 5727 (Feb. 25,
1988).
In implementing section 469, Congress specifically
authorized the Secretary to prescribe regulations as to "what
constitutes * * * material participation". Sec. 469(l)(1).
Pursuant to that authorization, section 1.469-5T(a), Temporary
Income Tax Regs., 53 Fed. Reg. 5725 (Feb. 25, 1988), lists 7
alternative situations where an individual shall be treated, for
purposes of section 469, as materially participating in an
activity. Here, respondent relies on alternative (1) of that
temporary regulation, which provides that a taxpayer will be
considered to have materially participated in an activity if "The
individual participates in the activity for more than 500 hours
during * * * [the] year". Sec. 1.469-5T(a)(1), Temporary Income
Tax Regs., 53 Fed. Reg. 5725 (Feb. 25, 1988). (At trial
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