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    | Instructions for Form 8582-CR | 2006 Tax Year |  
                  
                  
This is archived information that pertains only to the 2006 Tax Year. If youare looking for information for the current tax year, go to the Tax Prep Help Area.
 
                     
                     Convert any current year qualified expenditures into credits before beginning Worksheet 1, 2, 3, or 4. If the credits are
                        from more than one
                        activity or are of more than one type, separate the credits by activity or type before making entries in the worksheets.
                        
                      Example. You have a low-income housing credit from one activity and a research credit from a different activity. Enter the low-income
                           housing credit in
                           column (a) of Worksheet 2 or 3 and make a separate entry for the research credit in column (a) of Worksheet 4.
                           
                        Form 3800, General Business Credit.
                                Enter the credits from Form 3800, line 3, in column (a) of Worksheet 1, 2, 3, or 4.
                        
                         Form 6478, Credit for Alcohol Used as Fuel.
                                 Enter the credits from Form 6478, line 7, in column (a) of Worksheet 1 or 4.
                        
                         Form 8834, Qualified Electric Vehicle Credit.
                                Enter the credits from Form 8834, line 11, in column (a) of Worksheet 1 or 4.
                        
                         Form 8835, Renewable Electricity, Refined Coal, and Indian Coal Production Credit.
                                Enter the credits from Form 8835, line 25, in column (a) of Worksheet 1 or 4.
                        
                         Form 8844, Empowerment Zone and Renewal Community Employment Credit.
                                Enter the credits from Form 8844, line 5, in column (a) of Worksheet 1 or 4.
                        
                         
                     
                        
                           
                              Prior Year Unallowed Credits
                               To figure this year's PAC, you must take into account any credits from passive activities disallowed for prior years and carried
                        forward to this
                        year.
                        
                      If you had only one type of prior year unallowed credit from a single passive activity, figure your prior year unallowed credit
                        by subtracting line
                        37 of your 2005 Form 8582-CR from line 5 of your 2005 Form 8582-CR.
                        
                      Otherwise, your prior year unallowed credits are the amounts shown in column (b) of Worksheet 9 in the 2005 Instructions for
                        Form 8582-CR. Enter
                        the prior year unallowed credits in column (b) of Worksheet 1, 2, 3, or 4, whichever applies.
                        
                      
                     
                        
                           
                              Part I—2006 Passive Activity Credits
                               Use Part I to combine your credits from passive activities to determine if you have a PAC for 2006.
                        
                      If your credits from all passive activities exceed the tax attributable to net passive income, you have a PAC for 2006. Generally,
                        you have net
                        passive income if line 4 of Form 8582 shows income. For more information, see the instructions for Form 8582-CR, line 6, on
                        this page.
                        
                      Lines 1a through 1c.
                                Individuals and qualifying estates that actively participated in rental real estate activities must include the credits
                        (other than rehabilitation
                        credits or low-income housing credits) from these activities on lines 1a through 1c. Use Worksheet 1
                        to figure the amounts to enter on lines 1a and 1b.
                        
                         
                                See Special Allowance for Rental Real Estate Activities  on page 3.
                        
                         
                        If you are married filing a separate return and lived with your spouse at any time during the year, even if you actively participated
                        in the rental
                        real estate activity, include the credits in Worksheet 4, not in Worksheet 1.
                        
                         Note.
                                   You may take credits that arose in a prior tax year (other than low-income housing and rehabilitation credits) under
                           the special allowance only if
                           you actively participated in the rental real estate activity for both that prior year and this year. If you did not actively
                           participate for both
                           years, include the credits in Worksheet 4, not in Worksheet 1.
                           
                            Lines 2a through 2c.
                                Individuals (including limited partners) and qualifying estates who had rehabilitation credits from rental real estate
                        activities or low-income
                        housing credits for property placed in service before 1990 must include the credits from those activities on lines 2a through
                        2c. Use Worksheet 2 to
                        figure the amounts to enter on lines 2a and 2b.
                        
                         
                                If you have low-income housing credits for property placed in service after 1989, include those credits in Worksheet
                        3 instead of Worksheet 2. If
                        you held an indirect interest in the property through a partnership, S corporation, or other pass-through entity, use Worksheet
                        3 only if you also
                        acquired your interest in the pass-through entity after 1989.
                        
                         Lines 3a through 3c.
                                Individuals (including limited partners) and qualifying estates who had low-income housing credits from rental real
                        estate activities for property
                        placed in service after 1989 must include those credits on lines 3a through 3c. If you held an indirect interest in the property
                        through a
                        partnership, S corporation, or other pass-through entity, use lines 3a through 3c only if you also acquired your interest
                        in the pass through entity
                        after 1989. Use Worksheet 3
                        to figure the amounts to enter on lines 3a and 3b.
                        
                         
                        Include the credits in Worksheet 4, but not in Worksheet 2 or 3, if you are married filing a separate return and lived with
                        your spouse at any time
                        during the year.
                        
                         Lines 4a through 4c.
                                Individuals must include on lines 4a through 4c credits from passive activities that were not entered on Worksheets
                        1, 2, or 3. Trusts must include
                        credits from all passive activities in Worksheet 4. Use Worksheet 4 to figure the amounts to enter on lines 4a and 4b.
                        
                         Line 6.
                                If Form 8582, line 4, shows net income or you did not complete Form 8582 because you had net passive income, you must
                        figure the tax on the net
                        passive income. If you have an overall loss on an entire disposition of your interest in a passive activity, reduce net passive
                        income, if any, on
                        Form 8582, line 4, to the extent of the loss (but not below zero) and use only the remaining net passive income in the computation
                        below. If you had a
                        net passive activity loss, enter -0- on line 6 and go to line 7.
                        
                         
                                Figure the tax on net passive income as follows.
                        
                         
                           
                              
                              
                                 
                                    | A. | Taxable income including net passive income
 |  |  |  
                                    | B. | Tax on line A* |  |  
                                    | C. | Taxable income without net passive income |  |  |  
                                    | D. | Tax on line C* |  |  
                                    | E. | Subtract line D from line B and enter the result on
 Form 8582-CR, line 6
 |  |  
                           
                              
                              
                                 
                                    | * For Form 1040, use the Tax Table, Tax Computation Worksheet, or other appropriate method you used to figure your tax. For
                                       Form 1041, use the Tax Rate Schedules, Qualified Dividends Tax Worksheet, or Schedule D, whichever applies. |  
                           Note.When using taxable income in the above computation, it is not necessary to refigure items that are based on a percentage of
                              adjusted gross income.
                              
                            
                              
                                  
                                  
                               
                                 
                                     
                                     
                                  Worksheets 1 and 2 (Form 8582-CR). Summary: Worksheet 1 (used to determine the credit amounts to enter on Form 8582-CR, lines 1a and 1b, pertaining to rental
                                    real estate
                                    activities with active participation) and Worksheet 2 (used to determine the credit amounts to enter on Form 8582-CR, lines
                                    2a and 2b, pertaining to
                                    rehabilitation credits from rental real estate activities) are printed here for the taxpayer's use.
                                  
                              
                            Line 7.
                                If line 7 is zero because the tax on the net passive income on line 6 is greater than your credits from passive activities
                        on line 5, all your
                        credits from passive activities are allowed. In this case, enter the amount from line 5 on line 37 and report the credits
                        on the forms normally used.
                        Do not complete Worksheets 5 through 9.
                        
                         
                     
                        
                           
                              Part II—Special Allowance for Rental Real Estate Activities With Active Participation
                               
                           
                        Married persons filing separate returns who lived with their spouses at any time during the year are not eligible to complete
                        Part II.
                        
                      Use Part II to figure the credit allowed if you have any credits from rental real estate activities in which you actively
                        participated (other than
                        rehabilitation credits and low-income housing credits). See Rental Activities on page 2 for details.
                        
                      Line 9.
                             Married persons filing separate returns who lived apart from their spouses at all times during the year must enter
                     $75,000 on line 9 instead of
                     $150,000. Married persons filing separate returns who lived with their spouses at any time during the year are not eligible
                     for the special allowance.
                     They must enter -0- on line 16 and go to line 17.
                     
                      Line 10.
                             To figure modified adjusted gross income, combine all the amounts used to figure adjusted gross income except do not
                     take into account:
                     
                      
                        
                           
                              Any passive activity loss as defined in section 469(d)(1), 
                              Any rental real estate loss allowed to real estate professionals (defined under Activities That Are Not Passive Activities on
                                 page 1), 
                              
                              Any overall loss from a PTP, 
                              The taxable amount of social security and tier 1 railroad retirement benefits, 
                              The deduction allowed under section 219 for contributions to IRAs and certain other qualified retirement plans, 
                              The domestic production activities deduction, 
                              The deduction allowed for one-half of self-employment taxes, 
                              The exclusion from income of interest from series EE and I U.S. savings bonds used to pay higher education expenses, 
                              The exclusion of amounts received under an employer's adoption assistance program, 
                              The student loan interest deduction, or
                              The tuition and fees deduction. 
                        
                            
                            
                         
                           
                               
                               
                            Worksheets 3 and 4 (Form 8582-CR). Summary: Worksheet 3 (used to determine the credit amounts to enter on Form 8582-CR, lines 3a and 3b, pertaining to low-income
                              housing credits
                              and Worksheet 4 (used to determine the credit amounts to enter on Form 8582-CR, lines 4a and 4b, pertaining to credits from
                              all other passive
                              activities) are printed here for the taxpayer's use.
                            
                             Include in modified adjusted gross income any portfolio income and expenses that are clearly and directly allocable
                     to portfolio income. Also
                     include any income that is treated as nonpassive income, such as overall gain from a PTP and net income from an activity or
                     item of property subject
                     to the recharacterization of passive income rules. For information on recharacterization of income, see Pub. 925 or Temporary
                     Regulations section
                     1.469-2T(f).
                     
                      
                             When figuring modified adjusted gross income, any overall loss from an entire disposition of an interest in a passive
                     activity is taken into
                     account as a nonpassive loss if you do not have any net passive income after combining net income and losses from all other
                     passive activities (that
                     is, Form 8582, line 4 is a loss or zero). If you do have net passive income when you combine the net losses and net income
                     from all other passive
                     activities, the overall loss from the disposition is taken into account as a nonpassive loss only to the extent that it exceeds
                     that net passive
                     income.
                     
                      Line 12.
                             Do not enter more than $12,500 on line 12 if you are married filing a separate return and you and your spouse lived
                     apart at all times during the
                     year. Married persons filing separate returns who lived with their spouses at any time during the year are not eligible for
                     the special allowance.
                     They must enter -0- on line 16 and go to line 17.
                     
                      Line 15.
                             Figure the tax attributable to the amount on line 14 as follows.
                     
                      
                        
                           
                           
                              
                                 | A. | Taxable income |  |  |  
                                 | B. | Tax on line A* |  |  
                                 | C. | Enter amount from Form 8582-CR, line 14 |  |  |  
                                 | D. | Subtract line C from line A |  |  |  
                                 | E. | Tax on line D* |  |  
                                 | F. | Subtract line E from line B and enter the result on
 Form 8582-CR, line 15
 |  |  
                        
                           
                           
                              
                                 | * For Form 1040, use the Tax Table, Tax Computation Worksheet, or other appropriate method you used to figure your tax. For
                                    Form 1041, use the Tax Rate Schedules, Qualified Dividends Tax Worksheet, or Schedule D, whichever applies. |  
                        Note.When using taxable income in the above computation, it is not necessary to refigure items that are based on a percentage of
                           adjusted gross income.
                           
                         
                     
                        
                           
                              Part III—Special Allowance for Rehabilitation Credits From Rental Real Estate Activities and Low-Income Housing Credits for
                                 Property Placed in Service Before 1990 (or From Pass-Through Interests Acquired Before 1990)
                               
                           
                        Married persons filing separate returns who lived with their spouses at any time during the year are not eligible to complete
                        Part III.
                        
                      Use Part III to figure the credit allowed if you have any rehabilitation credits or low-income housing credits for property
                        placed in service
                        before 1990. Also use this part if your low-income housing credit is from a partnership, S corporation, or other pass-through
                        entity in which you
                        acquired your interest before 1990, regardless of the date the property was placed in service.
                        
                      Line 21.
                             Married persons filing separate returns who lived apart from their spouses at all times during the year must enter
                     $125,000 on line 21, instead of
                     $250,000.
                     
                      
                             Skip lines 21 through 26 if you completed Part II of this form and your modified adjusted gross income on line 10
                     was $100,000 or less ($50,000 or
                     less if married filing separately and you lived apart from your spouse for the entire year). Instead, enter the amount from
                     line 15 on line 27.
                     
                      Line 24.
                             Do not enter more than $12,500 on line 24 if you are married filing a separate return and lived apart from your spouse
                     for the entire year.
                     
                      Line 27.
                             Figure the tax attributable to the amount on line 26 as follows.
                     
                      
                        
                           
                           
                              
                                 | A. | Taxable income |  |  |  
                                 | B. | Tax on line A* |  |  
                                 | C. | Enter amount from Form 8582-CR, line 26 |  |  |  
                                 | D. | Subtract line C from line A |  |  |  
                                 | E. | Tax on line D* |  |  
                                 | F. | Subtract line E from line B and enter the result on Form 8582-CR, line 27 |  |  
                        
                           
                           
                              
                                 | *For Form 1040, use the Tax Table, Tax Computation Worksheet, or other appropriate method you used to figure your tax. For
                                    Form 1041, use the Tax Rate Schedules, Qualified Dividends Tax Worksheet, or Schedule D, whichever applies. |  
                        Note.When using taxable income in the above computation, it is not necessary to refigure items that are based on a percentage of
                           adjusted gross income.
                           
                         
                     
                        
                           
                              Part IV—Special Allowance for Low-Income Housing Credits for Property Placed in Service After 1989
                               
                           
                        Married persons filing separate returns who lived with their spouses at any time during the year are not eligible to complete
                        Part IV.
                        
                      Use Part IV to figure the credit allowed if you have any low-income housing credits for property placed in service after 1989.
                        If you held an
                        indirect interest in the property through a partnership, S corporation, or other pass-through entity, use Part IV only if
                        your interest in the
                        pass-through entity was also acquired after 1989.
                        
                      Line 35.
                                Figure the tax attributable to the remaining special allowance as follows.
                        
                         
                           
                              
                              
                                 
                                    | A. | Taxable income |  |  |  
                                    | B. | Tax on line A* |  |  
                                    | C. | Enter $25,000 ($12,500 if married filing separate return and you and your spouse lived apart at
                                       all times during the year) |  |  |  |  
                                    | D. | Enter amount, if any, from Form
 8582, line 10
 |  |  |  |  
                                    | E. | Enter the amount, if any, from Form
 8582, line 14
 |  |  |  |  
                                    | F. | Subtract lines D and E from line C
 |  |  |  
                                    | G. | Subtract line F from line A |  |  |  
                                    | H. | Tax on line G* |  |  
                                    | I. | Subtract line H from line B |  |  
                                    | J. | Add lines 16 and 30 of Form 8582-CR and enter the total
 |  |  
                                    | K. | Tax attributable to the remaining special allowance. Subtract line J from line I. Enter the result on
 Form 8582-CR, line 35
 |  |  
                           
                              
                              
                                 
                                    | *For Form 1040, use the Tax Table, Tax Computation Worksheet, or other appropriate method you used to figure your tax. For
                                       Form 1041, use the Tax Rate Schedules, Qualified Dividends Tax Worksheet, or Schedule D, whichever applies. |  
                           Note.When using taxable income in the above computation, it is not necessary to refigure items that are based on a percentage of
                              adjusted gross income.
                              
                            
                     
                        
                           
                              Part V—Passive Activity Credit Allowed
                               Use Part V to figure the PAC (as determined in Part I) that is allowed for 2006 for all passive activities.
                        
                      Line 37.
                                If you have only one type of credit, the amount on line 37 is the credit allowed for the year. Enter this amount on
                        the form where it is normally
                        reported. See Reporting Allowed Credits on Your Tax Return  below. Your unallowed credit is line 5 minus line 37.
                        
                         
                                Use Worksheets 5 through 9,
                        whichever apply, on pages 13 and 14, to allocate the allowed and unallowed credits
                        if you have credits from more than one activity. Also use the worksheets if you have more than one type of credit.
                        
                         
                                Keep a record of each unallowed credit and the activity to which it belongs so you may claim the credit if it becomes
                        allowable in a future year.
                        
                         
                        
                           
                              
                                 Reporting Allowed Credits on Your Tax Return Form 3800.
                                   Enter on Form 3800, line 5, the total passive activity general business credit allowed.
                           
                            Form 6478.
                                   Enter on Form 6478, line 9, the passive activity credit for alcohol used as fuel allowed.
                           
                            Form 8834.
                                   Enter on Form 8834, line 13, the passive activity qualified electric vehicle credit allowed.
                           
                            Form 8835.
                                   Enter on Form 8835, line 27, the passive activity renewable electricity, refined coal, and Indian coal production
                           credit allowed.
                           
                            Form 8844.
                                   Enter on Form 8844, line 7, the passive activity empowerment zone and renewal community employment credit allowed.
                           
                            
                           
                         
                           
                               
                               
                            
                              
                                  
                                  
                               Worksheets 5 and 6 (Form 8582-CR). Summary: Worksheet 5 (used to determine if all of the credits listed in Form 8582-CR, lines 1a and 1b, are allowed and Worksheet
                                 6 (used to
                                 determine if all of the credits listed in Form 8582-CR, lines 2a and 2b, are allowed) are printed here for the taxpayer's
                                 use.
                               
                           
                         
                           
                               
                               
                            
                              
                                  
                                  
                               Worksheets 7, 8, and 9 (Form 8582-CR). Summary: Worksheet 7 (used to determine if all of the credits listed in Form 8582-CR, lines 3a and 3b, are allowed), Worksheet
                                 8 (used to
                                 determine the allocation of unallowed credits), and Worksheet 9 (used to determine the credits allowed) are printed here for
                                 the taxpayer's
                                 use.
                               
                           
                         
                     
                        
                           
                              Publicly Traded Partnerships (PTPs)
                               A PTP is a partnership whose interests are traded on an established securities market or are readily tradable on a secondary
                        market (or its
                        substantial equivalent).
                        
                      An established securities market includes any national securities exchange and any local exchange registered under the Securities
                        Exchange Act of
                        1934 or exempted from registration because of the limited volume of transactions. It also includes any over-the-counter market.
                        
                      A secondary market generally exists if a person stands ready to make a market in the interest. An interest is treated as readily
                        tradable if the
                        interest is regularly quoted by persons, such as brokers or dealers, who are making a market in the interest.
                        
                      The substantial equivalent of a secondary market exists if there is no identifiable market maker, but holders of interests
                        have a readily
                        available, regular, and ongoing opportunity to sell or exchange their interests through a public means of obtaining or providing
                        information on offers
                        to buy, sell, or exchange interests. Similarly, the substantial equivalent of a secondary market exists if prospective buyers
                        and sellers have the
                        opportunity to buy, sell, or exchange interests in a timeframe and with the regularity and continuity that the existence of
                        a market maker would
                        provide.
                        
                      
                        
                        A credit from a passive activity held through a PTP is allowed to the extent of the tax attributable to net passive income
                           from that partnership.
                           In addition, rehabilitation credits and low-income housing credits from rental real estate activities held through PTPs are
                           allowed to the extent of
                           any special allowance that remains after taking into account losses and credits from rental real estate activities not owned
                           through PTPs. See
                           Special Allowance for Rental Real Estate Activities on page 3.
                           
                         
                              
                           Do not enter credits from PTPs on the worksheets or on Form 8582-CR. Instead, use the following steps to figure the allowed
                           and unallowed credits
                           from passive activities held through PTPs.
                           
                         
                        
                           
                              
                                 Computation of Allowed Passive Activity Credits From PTPs Complete Steps 1 and 2 only if you have net passive income from a PTP with passive activity credits (including prior year
                           unallowed credits).
                           
                         Step 1.
                                   Figure the tax attributable to net passive income from each PTP with passive activity credits (including prior year
                           unallowed credits) by following
                           the steps shown in the worksheet in the line 6 instructions on page 9. Complete a separate tax computation for each PTP with
                           net passive income.
                           
                            Step 2.
                                   Passive activity credits from each PTP are allowed to the extent of the tax attributable to net passive income from
                           the same PTP. Credits in excess
                           of the tax attributable to net passive income may be allowed under one or more steps below.
                           
                            
                                   Complete Steps 3 through 5 only if your passive activity credits (including prior year unallowed credits) include
                           rehabilitation credits from
                           rental real estate activities from PTPs, low-income housing credits for property placed in service before 1990 from PTPs,
                           or low-income housing
                           credits from PTPs in which you acquired your interest before 1990 (regardless of the date placed in service).
                           
                            Step 3.
                                   Reduce rehabilitation credits from rental real estate activities from each PTP, low-income housing credits for property
                           placed in service before
                           1990 from each PTP, and any low income housing credits (including prior year unallowed credits) from each PTP in which you
                           acquired your interest
                           before 1990 (regardless of the date placed in service) to the extent of the tax, which was figured in Step 1, attributable
                           to net passive income from
                           that PTP.
                           
                            Step 4.
                                   Before beginning this step, complete Form 8582-CR if you have any passive credits that are not from PTPs. Subtract
                           the total of lines 16, 30, and
                           36, if any, of Form 8582-CR, from the amount on line 27 of Form 8582-CR, to figure the tax attributable to the special allowance
                           available for the
                           credits in Step 3.
                           
                            
                                   If your only passive credits are from PTPs, complete lines 21 through 27 of Form 8582-CR as a worksheet. The amount
                           on line 27 is the tax
                           attributable to the special allowance available for the credits in Step 3.
                           
                            Step 5.
                                   Rehabilitation credits from rental real estate activities of PTPs, low-income housing credits for property placed
                           in service before 1990 by PTPs,
                           and low-income housing credits from PTPs in which you acquired your interest before 1990 (regardless of the date placed in
                           service) allowed under the
                           special allowance are the smaller of the total credits from Step 3 or the amount figured in Step 4. If Step 4 is smaller than
                           Step 3, allocate the
                           amount in Step 4 pro rata to the credits from each PTP in Step 3.
                           
                            
                                   Complete Steps 6 through 8 only if you have low-income housing credits (including prior year unallowed credits) for
                           property placed in service
                           after 1989 from a PTP in which you acquired your interest after 1989.
                           
                            Step 6.
                                   Reduce low-income housing credits (including prior year unallowed credits) for property placed in service after 1989
                           from each PTP in which you
                           also acquired your interest after 1989 to the extent of the tax attributable to net passive income from that PTP, which was
                           figured in Step 1.
                           
                            Step 7.
                                   Before beginning this step, complete Form 8582-CR if you have any passive credits that are not from PTPs. Subtract
                           the sum of the credits allowed
                           in Step 5 above and Form 8582-CR, line 36, from the amount on Form 8582-CR, line 35, to figure the tax attributable to the
                           special allowance available
                           for the credits in Step 6.
                           
                            
                                   If your only passive credits are from PTPs, complete the steps shown in the worksheet in the line 35 instructions
                           on page 12. Subtract the credits
                           allowed in Step 5 above from the tax figured on line K of that worksheet. The result is the tax attributable to the special
                           allowance available for
                           the credits in Step 6.
                           
                            Step 8.
                                   Low-income housing credits allowed under the special allowance for property placed in service after 1989 from a PTP
                           in which you also acquired your
                           interest after 1989 are the smaller of the total credits from Step 6 or the amount figured in Step 7. If Step 7 is smaller
                           than Step 6, allocate the
                           amount in Step 7 pro rata to the credits from each PTP in Step 6.
                           
                            Step 9.
                                   Add the credits from Steps 2, 5, and 8. These are the total credits allowed from passive activities of PTPs.
                           
                            Step 10.
                                   Figure the allowed and unallowed credits from each PTP. Report the allowed credits on the forms normally used. Keep
                           a record of the unallowed
                           credits to be carried forward to 2007.
                           
                            
                     
                        
                           
                              Part VI—Election To Increase Basis of Credit Property
                               Complete Part VI if you disposed of your entire interest in a passive activity and elect to increase the basis of the credit
                        property used in the
                        activity by the unallowed credit that reduced the basis of the property.
                        
                      Line 38.
                                Check the box if you elect to increase the basis of credit property used in a passive activity by the unallowed credit
                        that reduced the property's
                        basis. The election is available for a fully taxable disposition of an entire interest in an activity for which a basis adjustment
                        was made as a
                        result of placing in service property for which a credit was taken. You may elect to increase the basis of the credit property
                        immediately before the
                        disposition (by an amount no greater than the amount of the original basis reduction) to the extent that the credit had not
                        been allowed previously
                        because of the passive activity credit limitations. The amount of the unallowed credit that may be applied against tax is
                        reduced by the amount of the
                        basis adjustment.
                        
                         
                                No basis adjustment may be elected on a partial disposition of your interest in a passive activity or if the disposition
                        is not fully taxable. The
                        amount of any unallowed credit, however, remains available to offset the tax attributable to net passive income.
                        
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