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:: Passive Activity Loss Audit Technique Guide (ATG) - Table of Contents   Publication Date - December, 2004 NOTE: This guide is current through the publication date. Since changes may have occurred after the publication date that would affect the accuracy of this document, no guarantees are made concerning the technical accuracy after the publication date.   This Audit Techniques Guide (ATG) is presented in several chapters. These chapters can be accessed and then printed by following the links in the Table of Contents below. To print the entire ATG please refer to the PDF version. Table of Contents Introduction A Quick Look Inside! Chapter 1: Overview Introduction Types of Passive Activities What is Passive Activity Rules Participation Rules Form 8582 Summary Exhibit 1.1: Case Law and Ruling Exhibit 1.2: Form 8582- Line by Line Comment Exhibit 1.3: Common Issues Chapter 2: Rental Losses In a Nutshell The $25,000 Allowance In a Nutshell Active Participation Sub-Issue Modified Adjusted Gross Income Sub-Issue The $25,000 Allowance Supporting Law Exceptions to Rental Definition Real Estate Professional In a Nutshell Real Estate Professional Material Participation for Real Estate Pros Election to Group Rental Real Estate Real Estate Pro: Law Equipment Rentals In a Nutshell Equipment Leasing Supporting Law Vacation Rental In a Nutshell Material Participation Sub-Issue Summary Exhibit 2.1: Rental Decision Tree Exhibit 2.2: Modified Adjusted Gross Income Computation Exhibit 2.3: Rental Real Estate Losses: Active Participation Exhibit 2.4: Real Estate Professional Exhibit 2.5: Real Estate Professional- Interview Exhibit 2.6: Equipment Rentals Exhibit 2.7: Vacation Rentals/Condos/B&Bs/Hotels Chapter 3: Passive Income In a Nutshell Passive Income Supporting Law Self-Rental Income Lease Land Land Held for Investment Supporting Law Summary Exhibit 3.1: Passive Income Exhibit 3.2: Self-Rental Property- Income Recharacterization Exhibit 3.3: Passive Income Decision Tree Chapter 4: Material Participation In a Nutshell Activity Defined Grouping Activities Significant Participation Activities (SPA) Indicators What are My Issues Treatment of Former Passive Activities Methods of Proof Qualifying Participation General Rule Non-Qualifying Time Supporting Law Summary Exhibit 4.1: Material Participation Exhibit 4.2: Material Participation Decision Tree Exhibit 4.3: Significant Participation Activity (SPA) Exhibit 4.4: Activity Log Chapter 5: Dispositions In a Nutshell Entire Interest Partial Interest Fully Taxable Transaction Form 8582: Dispositions with Net Losses Dispositions with Overall Net Gains Form 8582: Dispositions with Net Gains Summary Supporting Law Exhibit 5.1: Dispositions Exhibit 5.2: Dispositions Triggering Losses Exhibit 5.3: Income Issues on Disposition of Passive Activity Chapter 6: Entity Issues Overview Material Participation for Corporations Personal Service Corporation Audit Considerations PSCs Audit Consideration on Closely Held C Corporations Supporting Law Trusts In a Nutshell Trust Rental Losses Supporting Law Trusts Material Participation Supporting Law Trusts Disposition, Distribution & Gifts Supporting Law Limited Liability Companies (LLCS) in a Nutshell Material Participation for LLCs Self-Charged Interest in a Nutshell Summary Exhibit 6.1: C Corporations: Passive Activity Issues Exhibit 6.2: Trusts Passive Loss Issues Exhibit 6.3: LLCs: Passive Activity Issue Exhibit 6.4: Self-Charged Interest Chapter 7: Interaction with other IRC Sections Introduction Investment Interest Expense Investment Income Investment Interest Expense Investment Interest Examination Techniques Investment Interest Supporting Law Rental of Personal Residence In a Nutshell Supporting Law Interest Issues Supporting Law Net Operating Losses Working Interests in Oil & Gas Property Trading Personal Property for an Owner’s Account Casualty Losses Low Income Housing Losses Summary Exhibit 7.1: Investment Income and Investment Interest Expense Exhibit 7.2: IRC§469(j)(7)-Interest on Rental Residence Chapter 8: Activities (Grouping Rules) In a Nutshell Five Factors Rentals Limited Partners C Corporations Partnerships and S Corporations Consistency Requirements Anti-Abuse Provisions Supporting Law Summary Exhibit 8.1: Activities (Grouping Entities) Chapter 9: Credits In a Nutshell Types of Credits Application of Credits Special Rental Real Estate Allowance Dispositions Supporting Law Summary Exhibit 9.1: Low Income Housing and Passive Loss Limitation Exhibit 9.2: Passive Loss Credit Decision Tree

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