79. Ray and Chuck own 50 percent capital and profits interests in Alpine Properties LLC. Alpine builds and manages rental real estate, and Ray and Chuck each work full time (over 1,000 hours per year) managing Alpine. Alpine’s debt

(both at the beginning and end of the year)

consists of $1,500,000 in nonrecourse mortgages obtained from an unrelated bank and secured by various rental properties. At the beginning of the current year, Ray and Chuck each had a tax basis of $250,000 in their respective LLC interest, including their share of the nonrecourse mortgage debt. Alpine’s ordinary business losses for the current year totaled $600,000, and neither member is involved in other activities that generate passive income.

a. How much of each member’s loss is suspended because of the tax-basis limitation?

b. How much of each member’s loss is suspended because of the at-risk limitation?

c. How much of each member’s loss is suspended because of the passive activity loss limitation? [Hint: See §469(c)(7).]

d. If both Ray and Chuck are single and Ray has a current-year loss of $50,000 from a sole proprietorship, how much trade or business loss can each deduct on their tax returns?