In a recent Tax Court decision, a taxpayer argued that he met the 750-hour requirement for materially participating in his rental real estate activities. The taxpayer, James Moss, asserted that because the time he spent “on call” related to his rental properties, the hours should be included in the 750-hour calculation. Moss claimed that whenever he was not at his regular job, he was on call because he could have been called to deal with a problem at the rental properties at any time.

Go to the U.S. Tax Court (www.ustaxcourt.gov) website and find the Moss decision. What did the Tax Court conclude about including “on-call” hours in the 750-hour requirement?