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Sec. 469(c). The record contains no evidence that petitioner
participated in the operations of Intelligent Systems.
Petitioner, in his brief or otherwise, fails to make any
credible argument that his share of the loss suffered by Intelli-
gent Systems is anything but a passive activity loss. For
example, on brief, he writes:
It is inconsistent and unfair to allow some businesses
effectively to integrate the corporate and shareholder
level taxes, by simply choosing to operate on a PTP
rather than corporation. The Congress has expressly
retained the double taxation of corporate income.
Similarly situated taxpayers--like the petitioner--
should be treated the same.
We do not see the import of petitioner's observations. Even if
petitioner were treated the same as a corporate shareholder, the
losses suffered by Intelligent Systems would be nondeductible by
petitioner. We conclude that this argument, like the remainder
of petitioner's arguments, lacks merit. Further, petitioner has
put on no evidence to rebut any of respondent's determinations.
Accordingly, we sustain the determinations in respondent's notice
of deficiency.
For the foregoing reasons,
Decision will be entered for
respondent.
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Last modified: May 25, 2011