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rental real estate activities as one activity for 1994 and 1995.
We hold that he did not.
Section references are to the Internal Revenue Code in
effect during the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
Background
The parties submitted this case fully stipulated under Rule
122.
A. Petitioner
Petitioner lived in Stamford, Connecticut, when he filed his
petition. He was a pilot for United Airlines in 1994 and 1995.
He worked 609 hours for United Airlines in 1994 and 681 hours in
1995.
B. Petitioner’s Rental Real Estate Activities
In 1994 and 1995, petitioner owned seven single and two-
family residential properties that he rented to others (the seven
properties). Six of the seven properties are in Stamford,
Connecticut, and one is in St. Petersburg, Florida. Petitioner
bought six of the properties from 1979 to 1984 and the seventh on
November 9, 1994. Petitioner performed 877 hours of service
relating to his real estate rentals in 1994 and 977 hours of
service in 1995. He did not use any of the seven properties for
personal purposes in 1994 or 1995.
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