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CONNOR v. C.I.R.

No. 99-3324.

218 F.3d 733 (2000)

Michael F. CONNOR and Jane H. Connor, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 5, 2000

Attorney(s) appearing for the Case

David J. Bohl (argued), Arthur Andersen, Milwaukee, WI, for petitioners-appellants.

Joel L. McElvain (argued), Department of Justice, Tax Division, Appellate Section, Washington, DC, for respondent-appellee.

Before FLAUM, RIPPLE and KANNE, Circuit Judges.

KANNE, Circuit Judge.

Michael and Jane Connor appeal a tax court decision finding a deficiency of $3,616 in their 1993 federal income tax and $6,089 in their 1994 federal income tax. This finding of deficiency arose from the determination that Michael Connor actively managed his personal services C corporation, which rents an office building owned by Jane Connor, and for this reason, the passive activity loss rules barred...

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