James V. and Judith M. Patterson - Page 8

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          Thus, we need not address whether the participation of other                
          individuals was greater than that of petitioners.                           
               We sustain respondent’s determination that the rental of the           
          condominium was a passive activity subject to the limitations of            
          section 469.                                                                
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               

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