James R. & Anita Madler - Page 12

                                                - 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