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Taxpayer fails to qualify as a real estate professional under PAL rules

Posted by Mike C Posted on Dec 28 2012

The Tax Court has concluded that a taxpayer, who also engaged in a consulting activity, wasn't a real estate professional for purposes of the passive activity loss (PAL) rules. He failed to show that more than half of the personal services that he performed during the year were performed in real property trades or businesses in which he materially participated. Kutney, TC Summary Opinion 2012-120