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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]".
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