- 4 - 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.Page: Previous 1 2 3 4
Last modified: May 25, 2011