Harnett v. Comr., No. 12-10636, 2012 U.S. App. LEXIS 23348 (11th Cir. Nov. 14, 2012)

(plaintiff, chairman of bank and real estate agent failed to qualify as real estate professional for purposes of exception to passive loss rules as applied to rental real estate activities; failure to meet 750-hour test due to lack of proof; burden of proof not shifted to IRS).