SCHWELB, Associate Judge:
The District of Columbia Department of Finance and Revenue (DFR) determined that appellants Everett K. Hobson and Nora E. Hobson, who are husband and wife, were not legally entitled to certain deductions for "passive activity losses" which they had claimed on their 1989 and 1990 District of Columbia income tax returns. The Hobsons sought review in the Superior Court, but that court granted summary judgment in favor of the District with respect...
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