Kutney v. Comr., T.C. Sum. Op. 2012-120

(petitioner, aeronautical engineer, owned several rental properties that he rented out and managed, and claimed losses from the rental activity for 2005-2007; IRS denied loss deductions on basis that petitioner subject to passive loss rules because petitioner failed to qualify as a real estate professional; court agreed with IRS because petitioner did not perform more than 50 percent of his personal services in real property trades or businesses; no contemporaneous log kept and testimony vague and indefinite; merely being on-call with respect to management services doesn't generate hours that can be counted toward 50 percent test).

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