MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine deficiencies of $36,441 and $35,962 in his 1994 and 1995 Federal income tax. We must decide whether petitioner is a real estate professional under section 469(c)(7). We hold he is not. Unless otherwise indicated, section references are to the Internal Revenue Code applicable to the relevant years. Rule references are to the Tax Court Rules of Practice and...
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