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Trustee's participation determines whether trust activity is passive under IRC Section 469 — In Private Letter Ruling 201029014 (July 23, 2010), the Internal Revenue Service explained how to determine whether an activity is “passive” under Internal Revenue Code Section 469, which disallows passive activity losses for individuals, estates, trusts, closely held C corporations and personal service corporations. Under IRC Section 469(c)(1), a passive activity is an activity
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