Dirico v. Comr., 139 T.C. No. 16 (2012)

(self-rental rule of Treas. Reg. 1.469-2(f)(6) held inapplicable to income petitioner received from wholly-owned S corporation for use of telecommunication towers and land leased to S corporation(which, in turn, leased towers to phone companies) because corporation's use of property constituted rental activity rather than trade or business; income from leases was income from passive activity and petitioner can offset losses against gains).