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Section 469(i) simply is an exercise by Congress of its broad
authority to recognize differences between various kinds of
activities. See Brushaber v. Union Pac. R.R., 240 U.S. 1 (1916).
As for the disallowance of the loss for other passive activities,
such as petitioner's automobile rental activity, the effect is an
incidental financial burden and not an impermissible
interference. See Maher v. Roe, 432 U.S. 464, 471 (1977); Black
v. Commissioner, 69 T.C. 505, 509-510 (1977).
We hold that the legislative classification provided by
section 469(i) is constitutional.
Petitioner has made other arguments that we have considered
in reaching our decision. To the extent that we have not
discussed these arguments, we find them to be without merit.
To reflect our disposition of the disputed issue, as well as
the parties' concessions,
Decision will be entered
for respondent as to the
deficiencies in taxes and for
petitioner as to the accuracy-
related penalty for 1994.
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