Patrick F. and Arlene G. Sheehy - Page 8

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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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