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POHOSKI v. COMMISSIONER

Docket No. 9027-96.

75 T.C.M. 1574 (1998)

T.C. Memo. 1998-17

George and Bozenna Pohoski v. Commissioner.

United States Tax Court.

Filed January 13, 1998.

Attorney(s) appearing for the Case

Philip Garrett Panitz, for the petitioners. Donna F. Herbert, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $28,143 deficiency in petitioners' 1993 Federal income tax, and an accuracy-related penalty of $2,662 pursuant to section 6662(a).

After concessions, we must decide: (1) Whether petitioners materially participated in the rental of their two Hawaiian condominiums for purposes of the passive activity loss rules pursuant to section 469(a); and (2) whether petitioners are...

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