Williams v. Commissioner

PER CURIAM: *

Petitioners-Appellants Larry Williams and Dora Williams (“Petitioners”) appeal the decision of the United States Tax Court which, based on stipulated facts, determined deficiencies totaling $26,322 in their income tax for tax years 2009 and 2010 in favor of Respondent-Appellee, the Commissioner of Internal Revenue (“Commissioner”). We affirm.'

I. Applicable Law

This dispute concerns whether the Petitioners may characterize certain income as arising from a “passive activity” under Internal Revenue Code § 469 and an associated regulation, Treasury Regulation § 1.469-2(f)(6). 1 In…