material participation not required only active participation
Active participation is the least-stringent test, in which the taxpayer does not need to have regular, continuous, and substantial involvement in the operations. Instead, a taxpayer is considered to actively participate if he or she makes management decisions in a significant and bona fide sense
if you don't actively participate either, it's difficult to understand what you do and the activity in general. Perhaps what you have is a partnership which would require filing form 1065.
