Consider the passive loss limitations (under IRC 469) discussed in the text.
What potential or actual abuse was Congress attempting to curtail?
Has Congress been successful in light of the fact that any suspended losses are ultimately allowed to be recognized upon the disposition of a passive activity?
Are you aware of any "unintended consequences" occurring as a result of the enactment of IRC 469 and the regulations there under?
Is IRC 469 simply an example of Congressional overkill? Why or why not?