MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $12,094 and $11,651 in petitioners' Federal income tax for 1996 and 1997, respectively. After concessions, the remaining issues for decision are: (1) Whether petitioner Judy Bailey (petitioner) was a real estate professional under section 469(c)(7) during 1997 and (2) whether petitioners materially participated in the operation of their Lake Arrowhead property during...
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