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interpretation in that the prohibition reflected in this
provision appears in similar terms and follows a list of specific
examples of passthrough items. S. Rept. 97-640 (1982), 1982-2
C.B. 718, 725; H. Rept. 97-826 (1982), 1982-2 C.B. 730, 737.
Although section 469(b) does not use the term "carryforward", we
think the phrase "shall be treated as a deduction * * * allocable
to such activity in the next taxable year" has the same meaning.
We think this is particularly true in the case of a closely held
C corporation where passive losses are available as deductions
against active losses. Our view in this respect is reinforced by
that fact that the Senate Finance Committee report, accompanying
the enactment of section 469, states that "Suspended passive
activity losses for the year are carried forward indefinitely,
but are not carried back" (emphasis added). S. Rept. 99-313
(1986), 1986-3 C.B. (Vol. 3) 1, 722; see also H. Conf. Rept. 99-
841 (Vol. II) (1986), 1986-3 C.B. (Vol. 4) 1, 137, describing the
Senate version of section 469 (there was no House of
Representatives version) as providing that "Disallowed losses and
credits are carried forward" (emphasis added). Moreover, while
we recognize that the use of captions is limited, see section
7806(a), we think it not amiss, in the context of this case, to
note that section 469(b) is entitled "Disallowed Loss or Credit
Carried to Next Year" (emphasis added).
Petitioner points to Congress' placement of section 469
within subchapter E, part II of the Code, entitled "Methods of
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