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Rental of Real Estate--Worksheet 1, petitioner reported net
income of $1,939, no current net loss for any property, prior
year unallowed loss of $215,860, and a total overall loss of
$213,921. On Statement 30, Form 8582, Allocation of Unallowed
Losses, and on Statement 31, Form 8582, Allowed Losses,
petitioner reported that his total loss and total unallowed loss
was $213,921.
On Statement 32, Form 8582, Summary of Passive Activities,
petitioner reported that each rental property except for 80 Lawn
Avenue, Stamford, Connecticut, had a passive gain or loss of
zero, that his prior years’ carryover after his current year net
rental activity income was $1,939, and that the total allowed
losses for 1994 reported on Form 8582, line 11, was $1,939.
On Statement 33, Form 8582, Modified AGI, petitioner
reported that his rental loss was $56,954. Petitioner attached
no other statements or other information relating to his first
Form 8582.
Petitioner did not attach a statement to his 1994 return
stating that he was electing to treat his real estate activities
as one activity. He did not combine his 1994 Schedule E rental
real estate losses with his previously suspended losses.
E. Final Regulations
Section 1.469-9(g), Income Tax Regs., providing how to make
an election under section 469(c)(7), became final on December 21,
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