T.C. Memo. 2004-222
UNITED STATES TAX COURT
ZACARIAS LAPID AND MA DELAILA LAPID, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18544-02. Filed October 4, 2004.
Gary R. Dettloff, for petitioners.
Gregory C. Okwuosah, for respondent.
MEMORANDUM OPINION
HOLMES, Judge: The petitioners, Zacarias and Ma Delaila
Lapid, are an extremely hardworking couple who used some of their
savings to buy five condominiums in Florida and one house in
Nevada. These investments were not profitable, and the Lapids
contest the Commissioner’s characterization and disallowance of
the resulting losses as passive activity losses within the
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