- 5 -- 5 -
to “rental real estate activities”. Id.; see also Frank v.
Commissioner, supra.
In sum, petitioner’s leasing of the aircraft is a rental
activity and, as such, is a passive activity under the statute
and the regulations. While petitioner may have materially
participated in the activity, material participation does not
exempt the activity from the passive loss rules contained in
section 469.
Decision will be entered
for respondent.
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Last modified: May 25, 2011