10.21 Carryover of Disallowed Losses

A loss disallowed in a current year by the at-risk limitation may be carried over and deducted in the next taxable year, provided it does not fall within the at-risk limits or the passive loss limits in that year. The loss is subject to an unlimited carryover period until there is an at-risk basis to support the deduction. This may occur when additional contributions are made to the business or when the activity has income which has not been distributed.

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Carryover Losses
Losses disallowed by at-risk rules are carried over and may be deductible in a later year.
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Gain from the disposition of property used in an at-risk activity is treated as income from the activity. In general, the reporting of gain will allow a deduction for losses disallowed in previous years to be claimed in the year of disposition.

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