discussed Cited as authority (rule) James M. Root & Valerie K. Root (2×) also: Cited "see" The Ninth Circuit affirmed our decision “[e]ssentially upon the basis of the Tax Court’s opinion.” Todd v. Commissioner, 682 F.2d at 208.

cited Cited "see" Lender Management, LLC, Marvin K. Lender Revocable Trust, Tax Matters Partner v. Commissioner See Todd v. Commissioner, 77 T.C. 246, 248 (1981), aff’d, 682 F.2d 207 (9th Cir. 1982).

discussed Cited "see" Johnsen v. Commissioner (2×) See Todd v. Commissioner, 77 T.C. 246 (1981), affd. per curiam 682 F.2d 207 (9th Cir. 1982); Birdneck Realty Corp. v. Commissioner, 25 B.T.A. 1084 (1932); Harrisburg Hospital Inc. v. Commissioner, 15 B.T.A. 1014 (1929).

discussed Cited "see, e.g." Hovis v. Commissioner See, e.g., Todd v. Commissioner , 77 T.C. 246 (1981) (loss sustained on the abandonment of a real estate venture was not attributable to a trade or business where the taxpayer neither commenced operations nor was previously involved in similar ventures), and the cases cited therein at 249-250, affd. per curiam 682 F.2d 207 (9th Cir. 1982) .

discussed Cited "see, e.g." Waddell v. Commissioner (2×) See also Todd v. Commissioner, 77 T.C. 246, 249-250 (1981), affd. per curiam 682 F.2d 207 (9th Cir. 1982). 25 We have held, however, that the preopening expense doctrine does not apply to amounts deductible under section 212(2), paid or incurred for the management, conservation, or maintenance of property held for the production of income.