If you invest in several activities, each is generally treated separately when applying the at-risk limitation on Form 6198. You generally may not aggregate basis, gains, and losses from the activities for purposes of at-risk limitations. Thus, income from one activity may not be offset by losses from another; the income from one must be reported while the losses from the other may be nondeductible because of at-risk limitations.
However, you may aggregate activities that are part of a business you actively manage. Activities of a business carried on by a partnership or S corporation qualify if 65% or more of losses for the year are allocable to persons who actively participate in management.
The law allows partnerships and S corporations to treat as a single activity all depreciable equipment (Section 1245 property) that is leased or held for lease and placed in service in any tax year. Furthermore, you may aggregate all partnership or S corporation activities within the four categories of films and videotapes, oil and gas properties, geothermal properties, and farms (10.17).
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