- 17 -
substantial basis during 1996 and 1997. They do not meet the
requirements of Test 7.
Conclusion
Respondent's determination that petitioners' business losses
for 1996 and 1997 constitute passive activity losses is
sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011