No Deductible Losses Attributable To House Not Held For Income Production Purposes

In this case, the petitioners, a married couple, owned some rental properties.  With respect to the property at issue, the couple had previously rented it.  However, during the years at issue (2007 and 2008) they didn't receive any rent and engaged in only minor attempts to sell the property.  The incurred a loss with respect to the property which they deducted.  The IRS denied the deduction on the basis that the petitioners did not engage hold the house for the years at issue for the purpose of producing income and there was no for-profit activity with respect to the house for the years in issue.  The court agreed with the IRS.  Robinson v. Comr., T.C. Memo. 2014-120.