Dear sjr:

I appreciate you. That really helped me to gain knowledge, resolve the issue and be confident to answer my client's question.

For your question:

"What do you mean by adding "material"? Unless your client manages the PTP I don't see how they can materially participate in the activity of the PTP."

Ans: I just thought tax payer  must be material to work on that risk investment and be allowed loss (like passive rental income) . I must remove the check "material" LOL. Thank you for helping me 

Because I saw my client's prior return 2021 tax year (I did not  prepare), Sche E page 2 (all different PTP income and loss are off set each other)  and un allowed loss flowed to form 8582..I dont know how he could get there :).

Again, many thanks to spend time for me at this tax seasoning time