Douglas E. Kahle, (1997)
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Douglas E. Kahle, (1997)
T.C. Memo. 1997-90
UNITED STATES TAX COURT DOUGLAS E. KAHLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19712-94. Filed February 20, 1997.P, an individual, owned rental real estate, which produced passive losses under sec. 469, I.R.C. P was also a partner in partnership A, which had nonpassive losses from a nonrental real estate operation. Held, P could not combine the rental operation and nonrental operation into a single undertaking, and thus could not deduct passive losses as active losses, because the resultant undertaking would not pass the common location/ownership test of sec. 1.469-4T(c)(2), Temporary Income Tax Regs., 54 Fed. Reg. 20544 (May 12, 1989), and becau...See the full content of this document
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