O’Connell v. Comr., T.C. Sum. Op. 2011-43

(petitioner not entitled to deduct losses associated with rental properties because such losses subject to passive activity limitations of I.R.C. Sec. 469; no election made to treat multiple rental interests as a single rental activity, so requirements of I.R.C. Sec. 469(c)(7)(B) had to be satisfied with respect to each activity; taxpayer failed to corroborate his assertions that more than one-half of personal services he performed in trades or businesses for the years at issue were performed in real property trades or businesses, and did not satisfy 750-hour requirement; taxpayer did not qualify as a real estate professional; accuracy-related penalty imposed).