- 37 -                                        
          claimed losses for the years in issue, the deductions are not               
          allowable because petitioners were not "at risk" within the                 
          meaning of section 465 with respect to the Huntington                       
          indebtedness.                                                               
          Section 465(a) limits the losses a taxpayer may deduct with                 
          respect to a particular activity to the "aggregate amount with              
          respect to which the taxpayer is at risk * * * for such activity".          
          Sec. 465(a); Alexander v. Commissioner, 95 T.C. 467, 469 (1990),            
          affd. without published opinion sub nom. Stell v. Commissioner,             
          999 F.2d 544 (9th Cir. 1993).  Section 465(c)(3)(A)(i) provides             
          that the "at risk" rules apply to each activity engaged in by the           
          taxpayer in carrying on a trade or business or for the production           
          of income.                                                                  
               A taxpayer's "at risk" amount includes the amount of money             
          and the adjusted basis of other property contributed by the                 
          taxpayer to the activity, section 465(b)(1)(A), as well as certain          
          amounts borrowed with respect to the activity.26  Sec.                      
          465(b)(1)(B).  For borrowed amounts relating to a particular                
          activity, a taxpayer is considered to be "at risk" where the                
          taxpayer is personally liable for repayment of such amounts or has          
          pledged assets unrelated to the business for which the money was            
          borrowed.  Sec. 465(b)(2)(A) and (B); Krause v. Commissioner, 92            
               26 The determination of the amount that a taxpayer has "at             
          risk" as to a given activity is made at the close of the taxable            
          year.  Sec. 465(a)(1).                                                      
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