Here, the petitioner was a merchant marine that spent much time away from home and rented his home to a friend. The rental amount was below fair market rental value, and the friend only paid for one month. The petitioner did not attempt to collect the unpaid rent amounts. The petitioner claimed a deduction for rental losses which IRS denied on the basis that the petitioner could not prove that he rented the home at market value and made no attempt to collect unpaid rent. The court upheld the IRS position, noting additionally that the petitioner could not establish his time spent away from home and not at sea. Hunter v. Comr., T.C. Memo. 2014-164