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RAMSBURG v. COMMISSIONER

Docket No. 6140-03.

90 T.C.M. 447 (2005)

T.C. Memo. 2005-252

Jacob R. Ramsburg, Jr. and Norma J. Ramsburg v. Commissioner

United States Tax Court.

October 31, 2005.

Attorney(s) appearing for the Case

David Samuel De Jong and Frank W. Dunham III, for petitioners.

Roger W. Bracken and Ann Welhaf, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined deficiencies of $69,505, $18,717, and $120,737 in petitioners' Federal income tax (tax) for 1996, 1997, and 1998, respectively.

The only issue remaining for decision1 is whether section 469(g)(1)2 permits petitioners to treat for 1998 certain losses from a passive activity (passive losses) as losses not from a passive...

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