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Summary Southern New Hampshire University TAX 700 - Short Paper 01:43:39 GMT -05:00 To: Tax

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Southern New Hampshire University TAX 700 - Short Paper 01:43:39 GMT -05:00 To: Tax Partner From: Luis Vanegas Date: January 10, 2024 Re: Private Letter Ruling (PLR) 9251003, 8/31/1992, IRC Sec(s). 469 Facts PLR 9251003 addresses a taxpayer involved in a real estate rental activity resulting...

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  • October 17, 2024
  • 5
  • 2024/2025
  • Summary

Subjects

  • 8311992
  • the i
  • southern new hampshire university tax 700 shor
  • 2024 re private letter ruling plr 9251003
  • irc secs 469 facts plr 9251003 addresses a t
  • seeking to offset losses against passive income

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Southern New Hampshire University

TAX 700 - Short Paper




01:43:39 GMT -05:00

, To: Tax Partner From:


Luis Vanegas Date:


January 10, 2024


Re: Private Letter Ruling (PLR) 9251003, 8/31/1992, IRC Sec(s). 469


Facts


PLR 9251003 addresses a taxpayer involved in a real estate rental activity resulting in

substantial losses. The taxpayer claimed active participation in the activity, seeking to offset

losses against passive income. However, the IRS raised concerns about the taxpayer's active

involvement based on the following facts:


● The taxpayer spent only 10 hours per week managing the rental properties.

● The taxpayer hired A property management company to handle most day-to-day tasks.

● The taxpayer needed to gain significant managerial or operational experience in real

estate.

● The taxpayer's primary occupation was in another field entirely.


Issues


The central issue in PLR 9251003 revolves around determining whether the taxpayer's

level of participation in the rental activity qualifies as "active participation" under IRC Section

469, thereby permitting the offsetting of passive income with the incurred losses.


01:43:39 GMT -05:00

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