Suspended Passive Losses Taken When Interest Entirely Disposed Of.

Here, the petitioner had passive losses that were not currently taken and were suspended.  The petitioner claimed that he disposed of his interest in the passive activities involved in the year that the bank foreclosed on the two properties involved.  However, the court disagreed because the foreclosure action was not final in that year.  Simply filing a final partnership return for the partnership that owned the properties was inadequate proof that a disposition had occurred.  Herwig v. Comr., T.C. Memo. 2014-95.