S Corporation Did Not Have Passive Rental Income.

An S corporation had rental income from a property that it leased to others.  The S corporation, through its officers, employees and independent contractors, provides various services with respect to the property including janitorial and trash removal, maintenance and repairs and inspection services.  The S corporation also provided security services.  The IRS determined that the rental income was not passive.  Priv. Ltr. Rul. 201523008 (Feb. 4, 2015).

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