7907. May a limited partner aggregate amounts he or she has “at risk” in different tax shelters in order to determine allowable deductions?Nuco Employeercline202014-07-07T22:32:00Z2014-07-07T22:32:00Z1165946Summit Business Media72110914Site Map/Investments/Special Rules/Limitation on Loss Deductions/At RiskTaxFactsDefaultArticle123191289-00-tf2.xml1289.00;#1956;#0x010100C568DB52D9D0A14D9B2FDCC96666E9F2007948130EC3DB064584E219954237AF3900242457EFB8B24247815D688C526CD44D009C4E67E972694125ABDA91AC61F5E51FTax Facts 2May a limited partner aggregate amounts he has “at risk” in different tax shelters in order to determine his allowable deductions?12900.0000000000TaxFactsDefaultArticleSBMEDIA\moss-admin2010-01-14T22:19:20Z7907. May a limited partner aggregate amounts he or she has “at risk” in different tax shelters in order to determine allowable deductions?No. The IRC requires that a limited partner apply the “at risk” limitations separately with respect to each limited partnership interest owned. The IRC also grants the Treasury Department authority to issue regulations requiring aggregation or separation of activities subject to the at risk rules; it is unclear what those regulations might require.IRC Sec. 465(c). See General Explanation–TRA ’84, p. 735.Furthermore, should one of the taxpayer’s limited partnerships be engaged in more than one activity covered by the at risk rules (e.g., oil exploration and equipment leasing), the taxpayer is generally required to treat each covered activity as a separate activity for purposes of applying the at risk limitations.IRC Sec. 465(c)(2)(A). See Temp. Treas. Reg. §1.465-1T. However, until otherwise provided, partnerships and S corporations can aggregate activities within each of certain categories for purposes of the at risk rules. The categories within which aggregation is permitted are oil and gas properties, geothermal properties, farms, and films and video tapes.Notice 89-39, 1989-1 CB 681.