- 10 - observe correctly that both the legislature and the judiciary have referred to the combating of “tax shelters” as one of the reasons for the enactment of section 469, we, unlike petitioners, do not read that term to require a finding of a specific intent to reduce taxes. Instead, we read that term plainly in the context of the setting at hand to include any transaction that, but for the recharacterization rule, would allow taxpayers to use passive losses to offset rental income received from a wholly owned business in which they actively participate. We hold once again that the recharacterization rule is valid. In so doing, we have considered all of petitioners’ arguments for a contrary holding and, to the extent not discussed above, find those arguments to be without merit or irrelevant. To reflect the foregoing, An appropriate order will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011