Office of Chief Counsel Internal Revenue Service
memorandum
Number: 201427016
Release Date: 7/3/2014
CC:PSI:B01:BHWeaver PRESP-144515-13
Third Party Communication: None
Date of Communication: Not Applicable
UILC: 469.14-00, 469.00-00
date: April 28, 2014
to: Kelly H. Myers, Technical Advisor (Passive Activity Losses & Real Estate) (Small Business/Self-Employed)
from: Laura C. Fields, Senior Technician Reviewer (Passthroughs & Special Industries)
subject: Application of the qualifying taxpayer rules of section 469 […]