Internal Revenue Code Section 469 - Passive Activity in Real Estate.
"The passive activity loss rules have developed into a complicated set of guidelines since their inception. If you keep in mind the and have a general understanding of the principles that drive loss limitations in this area, you will have a good foundation for selecting investment strategies that allow you to take full advantage of the passive activity rules."
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Pursuant to IRS Circular 230 regulation: "Any tax advice expressed was not intended or written to be used, and cannot be used, by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer. If this advice was written to support the promotion or marketing of partnership or other entity, investment plan, or arrangement to any taxpayer then the advice was written to support the promotion or marketing of the matters addressed by the written advice and the taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax adviser."