(petitioners, married couple, claimed NOL from LLC that was passed through to them; IRS denied NOL on basis that petitioner did not materially participate in the LLC; court determined that wife satisfied test by participating more than 500 hours during the year and satisfied the facts and circumstances test; petitioners' testimony credible; deductible losses limited by I.R.C. Sec. 1366(d)(1) to petitioners' adjusted basis of interest at end of LLC's tax year; 5 percent additional tax penalty applicable).
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