MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
For taxable years 1995 and 1996, respondent determined deficiencies of $11,620 and $5,994, respectively, in petitioners' Federal income taxes.
The primary issue for decision is whether petitioners' equipment rental activity constitutes a passive activity under section 469(c)(2).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable...
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