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rental activities. Accordingly, under section 163(d)(5)(A)(ii)
the rental properties are not “[properties] held for investment”,
and the income from them is not available to offset petitioner’s
investment interest.
Reviewed and adopted as the report of the Small Tax Case
Division.
An order of dismissal for
lack of prosecution will be entered
as to Carole Ritter, and decision
will be entered under Rule 155.
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Last modified: May 25, 2011