(petitioners, married couple, attempted to deduct losses from rental real estate activities; during years at issue, husband was real estate appraiser and wife had full time job at technology company; petitioners owned multiple real estate properties in various states and made grouping election via I.R.C. Sec. 469(c)(7)(A); real estate losses exceeded gross income on joint returns; IRS disallowed losses and court agreed; neither spouse satisfied real estate professional test due to lack of records and inconsistent testimony; active participation exception unavailable due to petitioners’ adjusted gross income exceeding $150,000; accuracy-related penalties imposed).