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NOTES 961 Tax Lawyer, Vol. 55, No. 4 NOTE THE REAL ESTATE EXCEPTION TO THE PASSIVE ACTIVITY RULES IN MOWAFI V. COMMISSIONER AND THE NEW BURDEN SHIFTING STATUTE In Mowafi v. Commissioner,1 the Tax Court held that the taxpayer did not meet the burden of proof required for the real estate professional exception to the passive activity rules.2 The court found that the taxpayer’s inconsistent testimoon combined with logs that were prepared two to three years after the activitiie supposedly occurred...