Alfredo A. and Jane R. Galagar - Page 7

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          is $148,937.  Petitioners’ adjusted gross income exceeds $100,000           
          by $48,937.  Fifty percent of $48,937 is $24,468 (rounded).  The            
          maximum offset amount is $25,000.  Thus, under section 469(i),              
          petitioners are entitled to a rental real estate loss of $532 for           
          taxable year 1998, the amount determined by respondent.                     
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


                                                  Decision will be entered            
                                             for respondent.                          





























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