Randy G. Sellers v. Commissioner

T.C. Memo. 2020-84

UNITED STATES TAX COURT RANDY G. SELLERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5742-18. Filed June 15, 2020. D. Loren Washburn, for petitioner. Randall Craig Schneider and Rebekah A. Myers, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION BUCH, Judge: For the years at issue, Mr. Sellers filed individual returns and returns on behalf of his businesses. On his individual returns and on the returns of one of his corporations, Mr. Sellers deducted nonpassive losses attributed to two passthrough entities: King’s Dominion Investments, LLC…