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AL ASSAF v. COMMISSIONER

Dkt. No. 770-03.

89 T.C.M. 694 (2005)

T.C. Memo. 2005-14

Assaf F. Al Assaf and Rehab Assaf v. Commissioner.

United States Tax Court.

January 31, 2005.

Attorney(s) appearing for the Case

Rehab R. Assaf, for petitioners;

William F. Castor, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined deficiencies of $8,940 for 1999 and $12,486 for 2000 in petitioners' Federal income taxes. The issue to be decided is whether the passive loss rules of section 4691 preclude petitioners from deducting leasing activity losses incurred by their wholly owned limited liability company. We hold that they do not.

FINDINGS OF FACT

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