- 4 - Year Loss 1988 $18,232 1989 12,231 In 1987, Associates sold two units of the Project, Pilot House 206 (unit 206) and Pilot House 405 (unit 405), to petitioner. During 1988 and 1989, petitioner rented out these units. He owned and rented out other units that are not the subject of this dispute. We shall refer to petitioner's rental of units 206 and 405 as the Rental Operation. Petitioner's gross income with respect to the Rental Operation was as follows: Unit 1988 1989 206 $5,166 -0- 405 7,200 -0- Petitioner incurred losses with respect to the Rental Operation as follows: Unit 1988 1989 206 $22,947 $26,703 405 23,115 30,966 In 1989, petitioner sold unit 405. Statutory and Regulatory Framework The issue before us is whether petitioner's Rental Operation should be classified as a nonpassive activity for purposes of section 469. That section was designed to limit deductions of losses from passive activities. S. Rept. 99-313 (1986), 1986-3 C.B. (Vol. 3) 713, 716-718. To this end, taxpayers generally mayPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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