- 12 - was regular, continuous, and substantial. Petitioners have not established that they materially participated in the activity in question; therefore, they are not entitled to claim as a deduction the losses in question. Accordingly, we sustain respondent's determination on this issue. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011