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Jane is a partner in the Cherize Partnership, which is not publicly traded. Jane shares a 50% interest in the profits and losses of Cherize.

Jane is a partner in the Cherize Partnership, which is not publicly traded. Jane shares a 50% interest in the profits and losses of Cherize. Cherizes passive ordinary losses from a nonrealty activity for the current year is ($800,000). Jane has a $250,000 adjusted basis (outside basis) for her interest in Cherize (before deduction of any of the passive losses). Her adjusted basis includes nonrecourse debt. Her amount "at risk" under 465 is $100,000 (before deduction of any of the passive losses). She also has $120,000 of passive income from other sources.

How much of the passive loss allocated to her can Jane deduct on her current year's tax return?

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