(petitioners, married couple, cannot deduct losses for wife's rental real estate activity due to limitations of passive loss rules and can't deduct them as start-up costs under I.R.C. Sec. 195; petitioners could not claim first-time homebuyer exception to 10 percent penalty under I.R.C. Sec. 72(t) because they had already received the $10,000 exception for first-time homebuyer at earlier point in time).