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1.469-2T(f)(6), Temporary Income Tax Regs., 53 Fed. Reg. 5686,
5723 (Feb. 25, 1988), served as the text of the proposed
regulations). The notice of proposed rulemaking complied with
the notice and comment requirements of the APA, supra; inter
alia, it set forth by cross-reference the substance of the
proposed regulations, including the subjects, issues, and rules
involved, and it invited written comments. 53 Fed. Reg. 5733.
The notice of proposed rulemaking also invited requests for a
public hearing and stated that a public hearing would be held,
upon the request of any commentator, at a time and place to be
published in the Federal Register. Id.
Section 1.469-4(a), Income Tax Regs., was prescribed by the
Commissioner under the broad regulatory authority that Congress
delegated to him through sections 469(l) and 7805, T.D. 8565,
1994-2 C.B. 81, 83, and is generally effective for taxable years
ending after May 10, 1992, sec. 1.469-11(a)(1), Income Tax Regs.
Section 1.469-4(a), Income Tax Regs., provides:
� 1.469-4. Definition of activity.--(a) Scope and
purpose. This section sets forth the rules for
grouping a taxpayer's trade or business activities and
rental activities for purposes of applying the passive
activity loss and credit limitation rules of section
469. A taxpayer's activities include those conducted
through C corporations that are subject to section 469
* * *. [Sec. 1.469-1T(b)(4), Temporary Income Tax
Regs., 53 Fed. Reg. 5686, 5701 (Feb. 25, 1988),
provides that a C corporation is subject to section 469
if it is a personal service corporation.]
The second sentence of section 1.469-4(a), Income Tax Regs.,
which contains the attribution rule in dispute, is a change from
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