Passive activity loss rules limit a taxpayer's ability to deduct losses generated by passive activities on their tax returns. However, a taxpayer who can show that he "materially participated" in an activity for the tax year generally can deduct the loss from the activity. Find a court case in which a taxpayer is deemed not to have been a material participant, and therefore their share of the losses is considered passive. Explain why the taxpayer failed the material participant test and why the court ruled against them. Included reference please.