- 24 - 13143(a), 107 Stat. 416, 440. The provisions of subsection (c)(7) of section 469 are effective for taxable years beginning after December 31, 1993. Id. sec. 13143(c), 107 Stat. 441. Two of the taxable years before us, 1992 and 1993, precede the effective date of the "Special rules for taxpayers in real property business" contained in subsection (c)(7). Thus, for those years petitioner may not rely on the special rules to relieve him of the generally applicable strictures of section 469 denying deductions for passive activity losses. Section 469(i), with respect to rental real estate activities in which an individual actively participates, provides that the section 469(a) disallowance will not apply to a maximum of $25,000 of passive activity losses.3 There is allowed only one $25,000 offset for all of petitioner's rental activities per year. Sec. 469(i)(2). For the year 1992, petitioner reported items on Schedule E. After taking into consideration rental (passive) income, petitioner reported individually owned real estate rental losses of $50,779, partnership real estate rental losses of $12,125, and 3This nonapplication or "exemption" begins to be phased out where the taxpayer's adjusted gross income exceeds a certain level, in some circumstances $100,000. Sec. 469(i)(3).Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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