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KELLY v. COMMISSIONER

Docket No. 2457-98.

79 T.C.M. 1427 (2000)

T.C. Memo. 2000-32

William Warren Kelly v. Commissioner.

United States Tax Court.

Filed January 28, 2000.

Attorney(s) appearing for the Case

William Warren Kelly, pro se. Robert V. Boeshaar, for the respondent.

MEMORANDUM OPINION

POWELL, Special Trial Judge:

Respondent determined deficiencies in petitioner's 1993 and 1994 Federal income taxes in the amounts of $1,631 and $2,014, respectively. The issue is whether petitioner's aircraft leasing activity is a passive activity under section 469.1 Petitioner resided in Springfield, Oregon, at the time he filed his petition.

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