Manalo v. Comr., T.C. Sum. Op. 2012-30

(petitioner was a real estate professional as a full-time real estate broker (worked at least 750 hours in real estate trades or businesses as an owner and worked more in real estate than in all of petitioner's other jobs), but did not satisfy the material participation test in either of petitioner's rental real estate activities; petitioner did not keep daily log of time spent on rental activities; accuracy-related penalties not imposed).