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Form 851 (Rev. December 2010)
The parent corporation must file Form 851 for itself and for corporations in the affiliated group. File Form 851 by attaching it to the consolidated tax return
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26 U.S. Code 469 - Passive activity losses and credits limited
Any loss or credit from an activity which is disallowed under subsection (a) shall be treated as a deduction or credit allocable to such activity in the next
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