- 16 - 6. Whether Petitioner Substantially Complied With the Requirement To Elect Under Section 469(c)(7) Petitioner contends that he substantially complied with the requirement to elect under section 469(c)(7). We disagree for reasons stated above. Petitioner has not shown that he gave respondent clear notice that he was making an election under section 469(c)(7) for 1994 or 1995. D. Conclusion Petitioner treated the rental real estate activities on his 1995 return in the same manner as his 1994 return. We conclude that petitioner did not elect on his 1994 or 1995 return to treat his rental real estate activities as a single activity under section 469(c)(7).5 To reflect the foregoing, Decision will be entered for respondent. 5 In light of our conclusion, we need not decide respondent’s contention that sec. 1.469-9(g), Income Tax Regs., requiring a taxpayer to attach a statement to his or her original return, applies to petitioner’s 1994 return.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011