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from this record that petitioners' participation during the years
in issue was greater than the participation of TMC's employees.
We conclude that petitioners did not materially participate
in the activity of renting their unit during 1991, 1992, and
1993. Accordingly, we hold that petitioners' claimed losses from
such activity constitute passive activity losses which are not
deductible in the taxable years in issue by reason of section
469. Cf. Oberle v. Commissioner, T.C. Memo. 1998-156; Chapin v.
Commissioner, T.C. Memo. 1996-56.
To reflect the foregoing,
Decision will be entered
for respondent.
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