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@rbynaker wrote:

Start with the math.  Couldn't there be a scenario with active participation where the rental loss results in an NOL that would need to be carried back?  Congress has flip-flopped so many times I can't keep track of which years can only be carried forward and which have to be elected-out of carry-back.

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I have stuck in my mind that it can't create a NOL.  But offhand, I don't have any citations for that.  😂