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activity
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When applying this recharacterization rule, the gross rental activity income for a tax year includes any passive activity gross income (determined without regard to the recharacterization rules) that is income for the year from the rental or disposition of the property; see Regs. Accordingly, the debt forgiveness income is characterized as passive activity gross income that can be offset only by passive activity deductions. 731(a) gain recognized by nonmaterial participants will be treated as passive activity gross income and netted against their passive activity suspended losses, according to Rev. |
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