David Burton examines the Tax Court’s recent analysis in Leland v. Commissioner, favoring a lawyer’s bid for exception from the passive activity loss rules for his ‘‘material participation’’ of more than 100 hours per year in operations of a farm he owns in another state. ‘‘The application of the greater-than-100-hours standard appears to be a fertile area for litigation,’’ the author writes.
Tax Court Sheds Light on Counting Hours For the ‘Material Participation’ Exception to the Passive Activity Loss Rules
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