-57-
(i) the taxpayer actively
participates in the management of
such trade or business, or
(ii) such trade or business is
carried on by a partnership or an S
corporation and 65 percent or more
of the losses for the taxable year
is allocable to persons who
actively participate in the
management of the trade or
business.
(C) Aggregation or separation of
activities under regulations.--the secretary
shall prescribe regulations under which
activities described in subparagraph (A)
shall be aggregated or treated as separate
activities.
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