Douglas and Carole Ritter - Page 6

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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               
                                             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