- 6 - share of income from VBR’s trade or business activity of operating bowling alleys under the exception in section 1.469- 4(d)(1)(A), Income Tax Regs., on the ground that the rental activity is “insubstantial” in relationship to the business activity of VBR. Petitioner merely makes this assertion without citing any applicable authority and without any legal analysis. The record lacks any evidence to support the argument that the rental activity was insubstantial with respect to VBR’s trade or business. Therefore, we hold that petitioner cannot group together his rental activity and VBR’s trade or business for purposes of the passive activity loss limitations of section 469. For all the foregoing reasons, respondent’s determinations in the notice of deficiency are sustained. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011