Stephen S. Ziegler - Page 4

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          E against income from other sources in arriving at total income             
          for each such year.                                                         
               Respondent issued to petitioner a notice of deficiency                 
          (notice) with respect to his taxable years 1995 through 1999.  In           
          that notice, respondent determined petitioner’s claimed Aldus               
          Green loss for each of those years to be a passive activity loss            
          under section 469, allowed each such loss to the extent of income           
          from passive activities for each such year, and disallowed the              
          following amount of petitioner’s claimed Aldus Green loss for               
          each such year:                                                             

                                 Year          Amount                                 
                                 1995          $44,108                                
                                 1996          52,415                                 
                                 1997          44,495                                 
                                 1998          41,317                                 
                                 1999          48,773                                 
               Petitioner concedes that petitioner’s claimed Aldus Green              
          loss for each of the years at issue is a passive activity loss as           
          defined in section 469(d)(1) and that section 469(a) disallows              
          each such loss.3  It is petitioner’s position, however, that the            
          application of section 469 to petitioner’s claimed Aldus Green              

               3Petitioner also concedes that he is liable for additions to           
          tax under sec. 6651(a)(1) for the taxable years 1996 and 1997 and           
          for accuracy-related penalties under sec. 6662(a) for all the               
          taxable years at issue.                                                     

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