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The benchmarking exercise included review of compensation and benefits for the State of New York and the State of New Jersey and significant public authorities in the New York City metropolitan region. In addition, with respect to compensation benchmarking of the Port Authority’s four largest line departments, five to seven public sector agencies and five to ten private sector companies were initially identified and reviewed for as potential peer comparables. Key business attributes of each potential peer were carefully scrutinized (e.g., size of operation, number and age of facilities, operator vs. infrastructure provider, etc.). Ultimately, a smaller subset of peer groups was selected for each line department of the Port Authority based on review of these attributes (please refer to Appendix – A for details). . | Internal Revenue Service Passive Activity Loss Audit Technique Guide ATG NOTE This guide is current through the publication date. Since changes may have occurred after the publication date that would affect the accuracy of this document no guarantees are made concerning the technical accuracy after the publication date. This material was designed specifically for training purposes only. Under no circumstances should the contents be used or cited as sustaining a technical position. The taxpayer names and addresses shown in this publication are hypothetical. They were chosen at random from a list of names of American colleges and universities as shown in Webster s Dictionary or from a list of names of counties in the United States as listed in the U.S. Government Printing Office Style Manual. Department of the Treasury Internal Revenue Service www.irs.gov Training 3149-115 02-2005 Catalog Number 83479V Passive Activity Loss Audit Technique Guide TABLE OF CONTENTS Introduction A Quick Look Inside Chapter 1 Overview Introduction.1-1 Types of Passive Activities.1-1 What is Passive.1-1 Activity Rules.1-2 Participation Rules.1-3 Form 8582.1-4 Summary.1-5 Exhibit 1-1 Case Law and Ruling.1-7 Exhibit 1-2 Form 8582- Line by Line Comment.1-13 Exhibit 1-3 Common Issues.1-15 Chapter 2 Rental Losses In a Nutshell.2-1 The 25 000 Allowance In a Nutshell.2-1 Active Participation Sub-Issue.2-2 Modified Adjusted Gross Income Sub-Issue.2-2 25 000 Allowance Supporting Law.2-3 Exceptions to Rental Definition.2-3 Real Estate Professional In A Nutshell.2-4 Real Estate Professional.2-4 Material Participation for Real Estate Pros.2-6 Election to Group Rental Real Estate.2-7 Real Estate Pro Law.2-7 Equipment Leasing Supporting Law.2-8 Vacation Rentals In a Nutshell.2-9 Material Participation Sub-Issue.2-9 Summary.2-11 Exhibit 2.1 Rental Decision Tree.2-13 Exhibit 2.2 Modified Adjusted Gross Income Computation.2-14 Exhibit 2.3 Rental Real Estate Losses Active Participation.2-17 Exhibit 2.4 .
