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partnership. Their characterizations about petitioner's
participation in RCC are not supported by the record. According
to the exhibits, petitioner's only contribution to the running of
RCC was checks totaling $50,000. Moreover, petitioners
misconstrue Mr. Cleveland's contribution to his partnership,
characterizing it as "cash invested and attending to some
paperwork." Cleveland has been interpreted to mean that an
active role is necessary to qualify as being in a trade or
business:
Furthermore, the court in Cleveland did not hold that
the act of financing research in itself constitutes the
trade or business of promoting an invention. The
combined activities of both participants in the joint
venture formed the basis for the court's finding of a
trade or business. * * *
Green v. Commissioner, supra at 691. Petitioners have not shown
that petitioner did any more than provide financing.
Neither does Green v. Commissioner, supra, support
petitioners' entitlement to a deduction. The taxpayers in Green
were limited partners in a partnership called LaSala. LaSala was
organized to acquire, improve, and develop four inventions. Id.
at 668-669. On the day LaSala acquired the inventions, it
entered into an agreement with NPDC, a patent development
company. Under the agreement, NPDC was to research and develop
the inventions. Id. at 671. LaSala had no authority to direct
NPDC's efforts. Id. at 672. This Court held that LaSala
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