- 8 - prescribed by the Commissioner under the broad regulatory authority that Congress delegated to him through sections 469(l)(1) and 7805,2 T.D. 8417, 1992-1 C.B. 173-174, and is effective for taxable years ending after May 10, 1992, sec. 1.469-11(a)(1), Income Tax Regs. That section provides in relevant part: � 1.469-2. Passive activity loss.-- * * * * * * * * * * (f)(6) Property rented to a nonpassive activity. An amount of the taxpayer's gross rental activity income for the taxable year from an item of property equal to the net rental activity income for the year 2 In relevant part, sec. 469(l) provides: (l) Regulations.--The Secretary [or his delegate, see sec. 7701(a)(11)(B)] shall prescribe such regulations as may be necessary or appropriate to carry out provisions of * * * section [469], including regulations-- (1) which specify what constitutes an activity, material participation, or active participation for purposes of this section, (2) which provide that certain items of gross income will not be taken into account in determining income or loss from any activity * * *, (3) requiring net income or gain from a limited partnership or other passive activity to be treated as not from a passive activity * * * Sec. 7805(a) generally provides that the "Secretary * * * [or his delegate, see sec. 7701(a)(11)(B)] shall prescribe all needful rules and regulations for the enforcement of [the Internal Revenue Code]".Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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