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EDELBERG v. COMMISSIONER

Docket No. 14735-93.

70 T.C.M. 393 (1995)

T.C. Memo. 1995-386

Jay W. Edelberg and Caral S. Edelberg v. Commissioner.

United States Tax Court.

Filed August 14, 1995.

Attorney(s) appearing for the Case

Lloyd T. Asbury, Jacksonville, Fla., for the petitioners. Steve R. Johnson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge:

Respondent determined deficiencies of $18,242, $18,612, and $24,553, respectively, in petitioners' 1988, 1989, and 1990 Federal income tax. After settlement of some issues, the issue for decision is whether certain income received by petitioners during 1988, 1989, and 1990 qualifies as passive income under section 469.

All section references are to the Internal Revenue Code in effect for the years...

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