ROGERSON v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 5848-20.

T.C. Memo. 2022-49

MICHAEL J. ROGERSON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 12, 2022.


Attorney(s) appearing for the Case

Steven R. Mather , for petitioner.

Monica D. Polo and Samuel M. Warren , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

This deficiency case calls on us to apply the passive activity loss rules of section 469.1 Enacted by Congress as part of the Tax Reform Act of 1986, Pub. L. No. 99-514, § 501(a), 100 Stat. 2085, 2233, the rules limit a taxpayer's use of losses generated...

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