Syed Mohammad Jameel Hasan - Page 4

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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             

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