APRREAssociation of Professors and Researchers in Religious Education
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The taxpayers filed their tax return, claiming a rental loss on Schedule E; because their adjusted gross income was less than $150,000, they claimed all or a portion of the rental loss as active participation rental real estate (APRRE) loss under Sec.
The taxpayers in this case were required to show the income or loss from this activity on Schedule C, had to treat it as passive, were not entitled to the $25,000 APRRE loss deduction and could only use these passive losses either against income from passive activities or, in the event the activity was disposed of, treat them as ordinary losses in the year of disposition.
First, if the APRRE loss allowance is important to taxpayers, they will need to structure their rental activities such that the average rental period is greater than seven days.