Taxpayer is a partner in a partnership. The activities of the partnership are related to the partner investing in several businesses that issue K-1s to the partnership. There are close to 20-25 different K-1s issued every year. Each activity is similar to the other one in that the taxpayer provides consulting and advisory services to different businesses and turnarounds the investment every 4-5 years for a profit. In order to determine material participation and whether the activity is active or passive do we look at all the activities combined or each activity on its own. For example the taxpayer works over 500 hours in all the activities but does not do so if each activity is weighed on its own.
Any thoughts or guidance on whether the taxpayer will qualify for all the activities as passive or active.
Any thoughts or guidance on whether the taxpayer will qualify for all the activities as passive or active.
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