Alexander Firsow and Camilla Thomas-Firsow, a.k.a. Camilla Thomas - Page 4

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          Maryland (Port Deposit property).  The other was located at 2539            
          Harbor Lane, Sanibel, Florida (Sanibel property).                           
               The Sanibel property was rented for approximately 1 month              
          during 1999 and for approximately 3 weeks during 2000.  The Port            
          Deposit property was rented throughout 1999 and 2000. Petitioners           
          spent no more than 2 weeks per year at the Sanibel property,                
          performing maintenance work, but also fishing off the pier.                 
               Petitioners filed joint Federal income tax returns for the             
          1999 and 2000 taxable years.  For 1999, petitioners reported on             
          their Schedule E, Supplemental Income and Loss, a loss of $25,712           
          from rental real estate for the Port Deposit property and the               
          Sanibel property.  For 2000, petitioners reported a loss on                 
          Schedule E of $29,493 for the same properties.                              
               For each of the taxable years, the Schedule E filed by                 
          petitioners contained the following cautionary language:                    
          “Caution:  Your rental real estate loss * * * may be limited.               
          See page E-3 to find out if you must file Form 8582.  Real estate           
          professionals must complete line 42 on page 2.”  Despite this               
          language, petitioners left blank line 42 of Schedule E, dealing             
          with “Reconciliation for Real Estate Professionals”.  Moreover,             
          petitioners did not file a Form 8582, Passive Activity Loss                 
          Limitations, with either of their joint returns for 1999 and                
          2000.                                                                       








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