MEMORANDUM OPINION
COLVIN, Judge:
Respondent determined that petitioner is liable for deficiencies in income tax of $20,369 for 1994 and $24,747 for 1995.
The issue for decision is whether, as petitioner contends, petitioner elected under section 469(c)(7) to treat his seven rental real estate activities as one activity for 1994 and 1995. We hold that he did not.
Section references are to the Internal Revenue Code in effect during the years...
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