1. Compare and contrast the at-risk rules and passive activity limits. Discuss the purpose for each, and suggest as least two (2) tax-planning strategies for ensuring that the IRS allows passive losses in order to reduce your tax liability. Provide support for your suggestion.

2. Imagine that you are in the process of creating a new business structure and have to choose between a personal service corporation and one that is closely held. Consider the tax deductions, at-risk rules, and passive loss limitations, and recommend the type of structure that has the greatest potential to minimize your tax liability. Defend your position.