Thomas E. and Susan L. Truskowsky - Page 11

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          of the activity.  Work done by an individual as an investor in an           
          activity includes but is not limited to:  (1) Studying and                  
          reviewing financial statements or reports on operations of the              
          activity; (2) preparing or compiling summaries or analyses of the           
          finances or operations of the activity for the individual's own             
          use; and (3) monitoring the finances or operations of the                   
          activity in a non-managerial capacity.  Id.                                 
               Temporary regulations relating to the meaning of the term              
          "material participation" in section 469(h)(1) provide that, in              
          general, an individual shall be treated, for purposes of section            
          469 and the regulations thereunder, as materially participating             
          in an activity for the taxable year if and only if--(1) The                 
          individual participates in the activity for more than 500 hours             
          during such year; (2) the individual's participation in the                 
          activity for the taxable year constitutes substantially all of              
          the participation in such activity of all individuals (including            
          individuals who are not owners of interests in the activity) for            
          such year; (3) the individual participates in the activity for              
          more than 100 hours during the taxable year, and such                       
          individual's participation in the activity for the taxable year             
          is not less than the participation in the activity of any other             
          individual (including individuals who are not owners of interests           
          in the activity) for such year; (4) the activity is a                       
          "significant participation" activity for the taxable year, and              






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