Frank Aragona Trust, Paul Aragona, Executive Trustee v. Commissioner

142 T.C. No. 9

UNITED STATES TAX COURT FRANK ARAGONA TRUST, PAUL ARAGONA, EXECUTIVE TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15392-11. Filed March 27, 2014. T is a trust that owned rental real-estate properties and engaged in other real-estate activities. T’s rental real-estate activities would be considered per se passive activities under I.R.C. sec. 469(c)(2) unless T qualified for the exception found in I.R.C. sec. 469(c)(7). This exception is applicable if more than one-half of the personal services performed in trades or businesses by the taxpayer are…