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Instructions for Form 6198

(Rev. December 2024)
At-Risk Limitations
For use with Form 6198 (Rev. November 2024) or later revision

Section references are to the Internal Revenue section 1245(a)(3).                        interest in the activity other than as a 
Code unless otherwise noted.                                                              creditor or who is related under section 
                                                       Certain equipment leasing          465(b)(3)(C) to a person (except you) 
General Instructions                           !       activities by closely held C       having such an interest. However, this 
                                               CAUTION corporations are not subject to    does not apply to (a) amounts borrowed 
Purpose of Form                                the at-risk rules. See sections 465(c)(4), by a corporation from a person whose 
Use Form 6198 to figure:                       (5), and (6).                              only interest in the activity is as a 
                                                                                          shareholder of the corporation, or (b) 
The profit (loss) from an at-risk            4. Exploring for or exploiting oil and     amounts borrowed after May 3, 2004, 
activity for the current year                  gas resources.                             and secured by real property used in the 
(Part I),
The amount at risk for the current           5. Exploring for or exploiting             activity of holding real property (other 
year (Part II or Part III), and                geothermal deposits, as defined in         than mineral property) that, if 
The deductible loss for the current          section 613(e)(2).                         nonrecourse, would be qualified 
year (Part IV).                                                                           nonrecourse financing. See Pub. 925 for 
                                               6. Any other activity that is not          definitions.
  The at-risk rules of section 465 limit       included in (1) through (5) above.           4. Any cash or property contributed 
the amount of the loss you can deduct 
                                                                                          to the activity or to your interest in the 
to the amount at risk.                         Exception.    Holding real property 
                                                                                          activity that is:
  For more details, see Pub. 925,              placed in service before 1987 and 
Passive Activity and At-Risk Rules.            holding an interest acquired before 1987     a. Financed through nonrecourse 
                                               in a partnership, an S corporation, or     indebtedness or protected against loss 
Who Must File                                  other pass-through entity already          through a guarantee, stop-loss 
Form 6198 is filed by individuals              engaged in an activity of holding real     agreement, or other similar 
(including filers of Schedules C, E, and       property before 1987 are not affected by   arrangement; or
F (Form 1040 or 1040-SR)), estates,            the at-risk rules. This exception does not   b. Borrowed from a person who has 
trusts, and certain closely held C             apply to holding mineral property.         an interest in the activity other than as a 
corporations described in section 465(a)               A special exception to the at-risk creditor or who is related under section 
                                                                                          465(b)(3)(C) to a person (except you) 
                                               CAUTION business of a qualified C 
(1)(B), as modified by section 465(a)(3).      !       rules applies to a qualifying      having such an interest. However, this 
  File Form 6198 if during the tax year        corporation. See Pub. 925 for details.     does not apply to (i) amounts borrowed 
you, a partnership in which you were a                                                    by a corporation from a person whose 
partner, or an S corporation in which you                                                 only interest in the activity is as a 
were a shareholder had any amounts             Amounts Not at Risk                        shareholder of the corporation, or (ii) 
not at risk (see Amounts Not at Risk,          You are not considered at risk for any of  amounts borrowed after May 3, 2004, 
later) invested in an at-risk activity         the following.                             and secured by real property used in the 
(defined below) that incurred a loss.          1. Nonrecourse loans used to               activity of holding real property (other 
                                               finance the activity, to acquire property  than mineral property) that, if 
  You must file Form 6198 if you are                                                      nonrecourse, would be qualified 
                                               used in the activity, or to acquire your 
engaged in an activity included in (6)                                                    nonrecourse financing. See Pub. 925 for 
                                               interest in the activity (unless the 
under At-Risk Activities (see At-Risk                                                     definitions.
                                               nonrecourse loan is secured by your 
Activities below) and you have borrowed 
                                               own property that is not used in the 
amounts described in (3) under                                                              You do not have to file Form 6198 if 
                                               activity). However, you are considered 
Amounts Not at Risk (see Amounts Not                                                      you are engaged in an activity included 
                                               at risk for qualified nonrecourse 
at Risk, later).                                                                          in (6) under At-Risk Activities, earlier, 
                                               financing secured by real property used    and you only have amounts borrowed 
                                               in the activity of holding real property   before May 4, 2004, that are described 
At-Risk Activities                             (other than mineral property). See         in (3) above.
The at-risk limitation rules apply to          Qualified Nonrecourse Financing, later.
losses from the following activities                                                      Qualified Nonrecourse 
carried on as a trade or business or for       2. Cash, property, or borrowed 
the production of income.                      amounts used in the activity that are      Financing
  1. Holding, producing, or distributing       protected against loss by a guarantee,     Qualified nonrecourse financing is 
motion picture films or videotapes.            stop-loss agreement, or other similar      financing for which no one is personally 
                                               arrangement (excluding casualty            liable for repayment and is:
  2. Farming, as defined in                    insurance and insurance against tort       Borrowed by you in connection with 
section 464(e).                                liability).                                holding real property;
                                                                                          Secured by real property used in the 
  3. Leasing any section 1245                  3. Amounts borrowed for use in the         activity;
property, as defined in                        activity from a person who has an 
                                   Instructions for Form 6198 (Rev. 12-2024)  Catalog Number 50013J
Nov 22, 2024                    Department of the Treasury  Internal Revenue Service  www.irs.gov



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Not convertible debt; and                  Separation rules.  Your activity with          Partners and S corporation share-
Loaned or guaranteed by any federal,       respect to each film, videotape, section       holders. If you have a loss or a 
state, or local government, or borrowed      1245 property that is leased or held for       deduction from an earlier tax year that 
by you from a qualified person (defined      lease, farm, holding of real property, oil     you could not deduct because of the 
below).                                      and gas property (as defined in section        at-risk rules, these losses and 
  See Regulations section 1.465-27 for       614), or geothermal property (as               deductions must be included in the 
details, including rules for partnership     defined in section 614) that is not            current year amounts you enter in
liabilities and disregarded entities. This   aggregated with other activities under         Part I. For example, if your prior year 
section is effective for any financing       the above rules is treated as a separate       Schedule K-1 had a $1,500 loss in 
incurred on or after August 4, 1998, but     activity.                                      box 1, but because of the at-risk rules 
taxpayers can apply the section              Each investment that is not a part of a        your loss was limited to $500, include 
retroactively.                               trade or business is treated as a              both the $1,000 loss from your prior year 
                                             separate activity.                             and the amount from your current year 
                                                                                            Schedule K-1 on line 1 of Form 6198.
  A qualified person is a person who 
actively and regularly engages in the                                                       Closely held corporations.   A closely 
                                             Specific Instructions
business of lending money (for example,                                                     held corporation must apply the 
a bank or savings and loan association).     If you are engaged in more than one            limitation on the deduction for interest 
                                             at-risk activity or in both at-risk activities expense under section 163(j) before 
  A qualified person is not:                 and not-at-risk activities, you must           applying the at-risk limitations.
A person related to you unless the         allocate income, gains, losses, and 
person would be a qualified person but       deductions to each activity.                   Line 1
for the relationship and the nonrecourse     Partnerships and S corporations                Ordinary Income (Loss)
financing is commercially reasonable         must give their partners and                   Taxpayers other than partners or
and on the same terms as loans to            shareholders a separate statement of           S corporation shareholders.      Enter 
unrelated persons,                           income, expenses, and deductions for           your ordinary income or loss from the 
The seller of the property (or a person    each at-risk and not-at-risk activity.         at-risk activity without regard to the 
related to the seller), or
A person who receives a fee as a           When filling in Parts I, II, and III, enter    at-risk limitations. This is the amount 
result of your investment in the property    only amounts that relate to the activity       you get when you subtract your total 
(or a person related to that person).        included on this form. Use accepted tax        deductions (including prior year 
                                             accounting methods to figure the               deductions that were not allowed 
                                             amounts to enter.                              because of the at-risk rules) from your 
Aggregation or Separation                                                                   total income from the activity for the 
                                             If you are a partner or an S 
of Activities                                corporation shareholder, enter any items       current year.
File one form if your activities are listed  for the activity that are from your            Do not include on line 1 capital or 
under the aggregation rules. File a          investment in the activity or were             ordinary gains and losses from the sale 
separate form for each activity if your      passed through to you on Schedule K-1          or other disposition of assets used in the 
activities are listed under the separation   or a similar statement.                        activity or of an interest in the activity. 
rules.                                                                                      These amounts, casualty or theft gains 
                                             Description of activity. After the             and losses, and investment interest 
Aggregation rules.   All section 1245        description of the activity, if applicable,    expense are entered on lines 2a, 2b, 2c, 
properties that are leased or held for       enter the name and identifying number          and 4.
lease and placed in service in any tax       of the partnership or S corporation.
year of a partnership or an S corporation                                                   Partners and S corporation share-
are treated as one activity. A partner in a  Part I—Current Year Profit                     holders. Enter the amount from box 1 
partnership or an S corporation                                                             of your current year Schedule K-1 (Form 
shareholder can aggregate and treat as       (Loss) From the Activity,                      1065 or Form 1120-S) (plus any prior 
a single activity all of the properties of   Including Prior Year                           year ordinary loss that you could not 
that partnership or S corporation that       Nondeductible Amounts                          deduct because of the at-risk rules).
are included within each of categories 
(1), (2), (4), and (5) under At-Risk         Taxpayers other than partners or               Lines 2a, 2b, and 2c
Activities, earlier.                         S corporation shareholders.  If you            Gain (Loss)
                                             have losses or deductions from an 
  Activities described in (6) under          earlier tax year that you could not 
At-Risk Activities, earlier, that constitute deduct because of the at-risk rules,           Combine long- and short-term capital 
a trade or business are treated as one       include those amounts on the                   gains and losses and ordinary gains and 
activity if (a) the taxpayer actively        appropriate form or schedule of your           losses from the sale or other disposition 
participates in the management of that       current year tax return before starting        of assets used in the activity or of your 
trade or business, or (b) the business is    Part I. For example, if 2024 is the current    interest in the activity. Enter gains and 
carried on by a partnership or an S          year, and your 2023 Schedule C (Form           losses without regard to the at-risk 
corporation and 65% or more of the           1040 or 1040-SR) had a $1,500 loss on          limitations, the limitation on capital 
losses for the tax year are allocable to     line 31, but because of the at-risk rules      losses, or the passive activity loss 
persons who actively participate in the      your loss was limited to $500, include         limitations. If more than one item is 
management of the trade or business.         the $1,000 on your 2024 Schedule C             included on a line, attach a statement 
Similar rules apply to activities            (Form 1040 or 1040-SR) in Part V, Other        describing each item.
described in (1) through (5) under           Expenses, and identify it as a prior year 
At-Risk Activities, earlier.                 loss.                                          Do not include amounts on

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lines 2a and 2b that are included on        included on line 8 of Form 4952, and        or 1040-SR) gain of $3,100 on line 2a. 
line 2c. Enter the form number or           enter that amount on line 4 of              Line 5 shows a current year loss of 
schedule letter to the left of the entry    Form 6198. You must reduce the              $1,500. You report the $3,100 gain on 
space for line 2c. For example, if you file allowable investment interest deduction     Schedule D (Form 1040 or 1040-SR) 
Form 4684, Casualties and Thefts, and       on Form 4952 by the amount you carry        and can deduct $3,100 of the $4,600 
carry amounts from that form to Form        to Form 6198. If you filed Form 6198 for    loss on Schedule C (Form 1040 or 
4797, Sales of Business Property, either    the prior tax year, include on line 4 of    1040-SR). You complete Part II or Part III 
(a) enter the amounts attributable to the   your current year Form 6198 any             of Form 6198 and determine that only 
activity from Form 4684 on line 2c and      investment interest expense from the        $600 of the $1,500 excess loss on line 5 
enter “Form 4684” on the dotted line        prior tax year that was limited because     is deductible in the current year. You 
next to the entry space, or (b) enter the   of the at-risk rules.                       replace the $4,600 loss first entered on 
amount attributable to the activity                                                     Schedule C (Form 1040 or 1040-SR) 
carried from Form 4684 to Form 4797         Line 5                                      with $3,700 ($3,100 + $600), the total 
on line 2b. If you carry a loss from Form   Current Year Profit (Loss)                  loss allowed in the current year.
4684 to Schedule A (Form 1040 or 
1040-SR), enter on line 2c either the       If line 5 shows a current year profit, you  Part II—Simplified 
loss from Schedule A (Form 1040 or          may not have to complete the rest of this   Computation of Amount At 
1040-SR) or the loss from Form 4684.        form. Report all of the income, gains, 
Taxpayers other than partners or            deductions, and losses shown on lines 1     Risk
S corporation shareholders.   Include       through 4 on the forms and schedules        Part II is a simplified method of figuring 
on your current year Schedule D (Form       normally used, and attach them to your      your amount at risk. It can be used only 
1040 or 1040-SR), Form 4797, or other       tax return. Also attach Form 6198 and       if you know your adjusted basis in the 
forms and schedules any prior year          keep a copy for your records.               activity or in your interest in the 
                                                                                        partnership's or S corporation's at-risk 
losses that you could not deduct                                                        activity.
because of the at-risk rules.               If your current year profit is from a 
                                            passive activity and you have a loss        Part III is a longer method of figuring 
Partners and S corporation share-           from any other passive activity, see the    your amount at risk, which may allow a 
holders. Include on lines 2a, 2b, and       Instructions for Form 8582, Passive         larger amount at risk. You do not need to 
2c your current year gains and losses       Activity Loss Limitations, or the           complete Part II if you use Part III.
and prior year losses attributable to the   Instructions for Form 8810, Corporate 
activity that you could not deduct          Passive Activity Loss and Credit            Line 6
because of the at-risk rules.               Limitations, whichever applies.             Adjusted Basis on the First Day of 
Line 3                                               Even if you have a current year    Tax Year
                                                     profit on line 5, you may have 
Other Income and Gains From the             CAUTION!                                    Sole proprietors. Filers of Schedules 
                                                     recapture income if you 
Activity                                    received a distribution or had a            C and F (Form 1040 or 1040-SR) must 
                                            transaction during the year that reduced    not reduce the amount on this line by 
If you were a partner or S corporation      your amount at risk in the activity to less any liabilities. See Pub. 551, Basis of 
shareholder, include on line 3 other        than zero at the close of the tax year.     Assets, for rules on adjusted basis.
income and gains from Schedule K-1          See Pub. 925 for information on the         Partners. To figure the adjusted basis, 
that you did not include on lines 1         recapture rules.                            see Pub. 541, Partnerships.
through 2c.
                                                                                        S corporation shareholders.         To figure 
Line 4                                                                                  the adjusted basis, see the Instructions 
                                            If line 5 shows a current year loss, 
Other Deductions and Losses                 your loss may be limited to the income      for Form 1120-S.
From the Activity                           or gains, if any, included on lines 1, 2,            If the partnership or S 
                                            and 3. Separate the items of income,                 corporation is engaged in more 
If you were a partner or S corporation      gains, deductions, and losses on lines 1    CAUTION! than one at-risk activity or in 
shareholder, include on line 4 other        through 4. The income and gains are         both at-risk activities and not-at-risk 
deductions and losses from                  fully reportable on your tax return. The    activities, you must figure the part of 
Schedule K-1 that you did not include       deductions and losses are allowable         your adjusted basis that is allocable to 
on lines 1 through 2c.                      (subject to any other limitation such as    each at-risk activity. See Aggregation or 
                                            the passive activity rules) to the extent   Separation of Activities, earlier, to 
                                            of the income and gains. To determine       determine each at-risk activity in which 
If you have investment interest 
                                            the allowable portion of each deduction     a partnership or S corporation is 
expense from your at-risk activity, first 
                                            or loss, divide each deduction or loss      engaged.
complete Form 4952, Investment 
                                            from the activity by the total loss from 
Interest Expense Deduction, to figure 
                                            the activity on line 5. Then, multiply the 
your allowable investment interest                                                      Line 7
                                            total income and gains by this fraction.
deduction.                                                                              Increases for the Tax Year
                                            Complete the rest of the form to see 
                                                                                        Do not include the current year income 
If you have investment interest             how much, if any, of the excess loss can 
                                                                                        or gains shown on lines 1 through 3.
expense from other activities on            be deducted.
Form 4952, determine the allowable 
investment interest deduction               Example.    You have a Schedule C           Include changes during the current 
attributable to the at-risk activity        (Form 1040 or 1040-SR) loss of $4,600       tax year in amounts that increase your 
                                            on line 1 and a Schedule D (Form 1040       amount at risk, such as the following.

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 1. Net fair market value (FMV) of          financing (defined earlier under            Part III—Detailed 
property you own (not used in the           Qualified Nonrecourse Financing) used 
activity) that secures nonrecourse loans    to finance the activity, to acquire         Computation of Amount At 
used to finance the activity, to acquire    property used in the activity, or to        Risk
property used in the activity, or to        acquire your interest in the activity. Only If you completed Part III of Form 6198 
acquire your interest in the activity.      amounts included on line 6 can be           for this activity for the prior tax year, skip 
Include the nonrecourse loans on line 9     entered on line 9.                          lines 11 through 14. Then, see the 
(if included on line 6). Generally, the net 2. Cash, property, or borrowed              instructions for lines 15 and 16, and the 
FMV is determined when the property is      amounts protected against loss by a         instructions for line 18, later, to 
pledged as security for the loan.           guarantee, stop-loss agreement, or          determine the amounts to enter on 
 Do not enter the net FMV if (a) the        other similar arrangement. Enter this       those lines.
nonrecourse loan was from a person          amount only if it was included on line 6.       If the activity began on or after one of 
who has an interest in the activity other   Do not include items covered by             the effective dates shown below and 
than as a creditor or who is related        casualty insurance or insurance against     you did not complete Part III of Form 
under section 465(b)(3)(C) to a person      tort liability.                             6198 for this activity for the prior tax 
(except you) having such an interest,       3. Amounts borrowed from a person           year, skip lines 11 through 14. Enter -0- 
and (b) the activity is described in (1)    who has an interest in the activity other   on line 15 and complete the rest of Part 
through (5) (or (6) for amounts borrowed    than as a creditor or who is related        III.
after May 3, 2004) under At-Risk            under section 465(b)(3)(C) to a person 
Activities, earlier. However, (a) does not  (except you) having such an interest.       Effective Dates
apply to amounts borrowed by a              This does not apply to (a) amounts          Generally, the effective date is the first 
corporation from a person whose only        borrowed by a corporation from a            day of the first tax year beginning after 
interest in the activity is as a            person whose only interest in the           1975 if the activity is described in (1) 
shareholder of the corporation. See         activity is as a shareholder of the         through (4) under At-Risk Activities, 
Pub. 925 for definitions.                   corporation, or (b) amounts borrowed        earlier.
 2. Cash and the adjusted basis of          after May 3, 2004, and secured by real          If the activity is described in (5) under 
other property (determined at the time of   property used in the activity of holding    At-Risk Activities, earlier, the effective 
the contribution) contributed to the        real property (other than mineral           date is usually October 1, 1978, for 
activity during the tax year. However, if   property) that, if nonrecourse, would be    wells started after September 30, 1978. 
you used your own assets to repay a         qualified nonrecourse financing. Enter      Generally, a well started before October 
nonrecourse debt and you included an        these amounts only if they were             1, 1978, is not subject to the at-risk 
amount in (1) above, the amount             included on line 6 and not included         rules.
included as repayments cannot be more       under (1) or (2) above. This applies only 
than the amount by which the balance of     to activities described in (1) through (5)      The activity of holding real property is 
the loan at the time of repayment           under At-Risk Activities, earlier. See      subject to the at-risk rules for property 
exceeds the net FMV of property you         Pub. 925 for definitions and more           placed in service after 1986, and for an 
own (not used in the activity) that         details.                                    interest acquired after 1986 in an S 
secures the debt.                           4. Withdrawals and distributions            corporation, partnership, or other 
 3. Loans used to finance the activity,     during the tax year — both cash and the     pass-through entity engaged in an 
to acquire property used in the activity,   adjusted basis of noncash items (less       activity of holding real property. An 
or to acquire your interest in the activity nonrecourse liabilities to which the        activity of holding real property does not 
for which you are personally liable, and    noncash items are subject) — including      include the holding of mineral property. 
qualified nonrecourse financing (defined    assets used in the activity to repay        Holding mineral property may be 
earlier under Qualified Nonrecourse         certain debts.                              subject to at-risk limitations other than 
                                                                                        the special rules that apply to activities 
Financing). Do not enter amounts            5. Nonrecourse liabilities included         of holding real property.
included in (2) under Increases for the     on line 6 of property you contributed to 
Tax Year or on line 6.                      the activity.                                   In most cases, the effective date for 
 4. Percentage depletion for this year                                                  all other at-risk activities is the first day 
deducted in excess of the adjusted          Line 10b                                    of the first tax year beginning after 1978.
basis of depletable property for the        Amount At Risk                                  If you are a partner or an S 
activity.
                                                                                        corporation shareholder, the date you 
                                            If the amount on this line is smaller than  became a partner or shareholder may 
Line 9                                      your overall loss from the activity         determine whether you are subject to 
Decreases for the Tax Year                  (line 5), you may want to complete Part     the at-risk rules.
                                            III to see if Part III gives you a larger 
Do not include the current year             amount at risk.                             Line 11
deductions or losses shown on lines 1                If the amount on line 10b is zero, Investment in the Activity at the 
through 4.                                  !        you may be subject to the          Effective Date
                                            CAUTION  recapture rules. See Pub. 925.
 Include changes during the current                                                     Taxpayers other than partners or
tax year in amounts that decrease your                                                  S corporation shareholders. Use the 
amount at risk, such as the following.                                                  Line 11 Worksheet and its instructions 
 1. Nonrecourse loans (including                                                        to figure your investment in the activity 
recourse loans changed to nonrecourse                                                   at the effective date. Enter all amounts 
loans) other than qualified nonrecourse                                                 as of the effective date.

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Partners and S corporation share-         partnership or S corporation is engaged                                             the part that is allocable to the at-risk 
holders. Enter on line 11 the basis of    in both at-risk and not-at-risk activities,                                         activity on line 11.
your investment in the partnership or S   allocate your investment between the 
corporation at the effective date. If the at-risk and not-at-risk activities. Enter 

   Line 11 Worksheet—Figure Your Investment in the Activity at the 
                                   Effective Date                                                                               Keep for Your Records
(If the activity began on or after the effective date, do not complete this worksheet.)
1.   Cash on hand and in banks for the activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .           1.   
2.   Inventories for the activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.   
3a.  Cost or other basis of depreciable assets for the activity (see instructions 
     below) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   3a.   
b.   Accumulated depreciation for the activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                3b.   
4.   Adjusted basis of depreciable assets for the activity. Subtract line 3b from line 3a . . . . . . . . . . . . . . . . . . . . . . . . .                       4.   
5a.  Cost or other basis of depletable assets at the time contributed to the 
     activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5a.   
b.   Accumulated depletion taken on or after property was contributed to the 
     activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5b.   
6.   Adjusted basis of depletable assets for the activity. Subtract line 5b from line 5a . . . . . . . . . . . . . . . . . . . . . . . . . .                      6.   
7.   Adjusted basis of land for the activity (net of any amortization) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                7.   
8.   Other assets for the activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    8.   
9.   Cash basis taxpayer investment in the activity at the effective date. Add lines 1, 2, 4, 6, 7, and 8. Enter here and on 
     Form 6198, line 11. (Accrual basis taxpayers also complete lines 10a through 14 below to figure the amount to enter 
     on Form 6198, line 11.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    9.   
10a. Trade notes and accounts receivable for the activity . . . . . . . . . . . . . . . . . . . . .                     10a.  
b.   Reserve for bad debts for the activity (see instructions below) . . . . . . . . . . . . . . .                      10b.  
11.  Net receivables for the activity. Subtract line 10b from line 10a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                11.  
12.  Add lines 9 and 11 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   12.  
13.  Accounts payable for the activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      13.  
14.  Accrual basis taxpayer investment in the activity at the effective date. Subtract line 13 from line 12. Enter here and on 
     Form 6198, line 11 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   14.  
Worksheet Instructions
Lines 3a and 3b. See the instructions for line 16, item (2), earlier, for the rules on basis. Generally, the amounts for lines 3a and 3b can be taken directly from your 
depreciation schedule. Use the depreciation schedule you filed at the effective date, not the schedule for the current tax year.
Line 10b. If you use a reserve for bad debts, subtract from your accounts receivable the balance of the reserve on the effective date. But only subtract up to the amount you 
were allowed as a deduction under repealed section 166(c) for years before the effective date.

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Line 12 Worksheet—Figure Your Total Losses From Years Before the 
Effective Date for Which There Were Equal or Greater Amounts Not At 
Risk at Year End                                                                                                    Keep for Your Records
        (a)                     (b)            (c)                     (d)                                          (e)                                            (f)
     Year            Amount of loss for the  Amount not at risk at end Total amounts from                 Subtract (d) from (c)                                    Smaller of (b) or (e)
                                year         of year                   column (f) for all prior years

Total (include on Form 6198, line 12) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
Worksheet Instructions
Use the first line of the worksheet for the first year in which you had a loss and amounts not at risk. List each subsequent year in order. 
Column (d). For each year after the first year, enter the total amount in column (f) for all prior years. 
Example. You had losses in 1970, 1971, and 1975. At the end of each of those years, you had outstanding amounts not at risk of $1,000. You had losses of $500 in 1970, 
$300 in 1971, and $500 in 1975. 
 For 1970, you enter $500 in column (b), $1,000 in column (c), $1,000 in column (e), and $500 in column (f).
 For 1971, you enter $300 in column (b), $1,000 in column (c), $500 in column (d) (the total amount from column (f) for all prior years), $500 in column (e), 
 and $300 in column (f).
 For 1975, you enter $500 in column (b), $1,000 in column (c), $800 in column (d) (the total amount from column (f) for all prior years ($500 + $300)), $200 
 in column (e), and $200 in column (f). Of the $500 loss for 1975, only $200 is a loss for which there was an equal or greater amount not at risk at year end.
Your total loss from years before the effective date for which there were equal or greater amounts not at risk at year end is $1,000 (the total of the amounts in 
column (f)).

Line 12                                      end. Use the Line 12 Worksheet and its                       at the effective date. Enter this amount 
                                             instructions to figure this amount.                          only if it was included on line 11. Do not 
Increases at Effective Date                                                                               include items covered by casualty 
                                             Make all entries on a year-by-year                           insurance or insurance against tort 
Enter your share of amounts such as the      basis. Include amounts only for years                        liability.
following.                                   before the effective date. Do not                              3. Amounts outstanding at the 
 1. Net FMV of your own property             accumulate totals of earlier losses or                       effective date borrowed from a person 
(not used in the activity) that secures      nonrecourse debts.                                           who has an interest in the activity other 
nonrecourse loans used to finance the                 If you took a deduction for                         than as a creditor or who is related 
                                                                                                          under section 465(b)(3)(C) to a person 
activity, to acquire property used in the    !        percentage depletion for an item                    (except you) having such an interest. 
activity, or to acquire your interest in the CAUTION  of depletable property in excess 
activity that will be included on line 14.   of the adjusted basis of the property in a                   This does not apply to amounts 
Generally, the net FMV is determined         year for which you had a loss for the                        borrowed by a corporation from a 
when the property is pledged as              activity, subtract the amount of the                         person whose only interest in the 
security for a loan.                         excess from the loss for that year.                          activity is as a shareholder of the 
 Do not enter the net FMV if (a) the                                                                      corporation. Enter these amounts only if 
nonrecourse loan was from a person           Line 14                                                      they were included on line 11 and not 
who has an interest in the activity other                                                                 included under (1) or (2) above. This 
than as a creditor or who is related         Decreases at Effective Date                                  applies only to activities described in (1) 
under section 465(b)(3)(C) to a person                                                                    through (5) under At-Risk Activities, 
(except you) having such an interest,        Enter your share of amounts such as the                      earlier. See Pub. 925 for definitions and 
and (b) the activity is described in (1)     following.                                                   more details.
through (5) under At-Risk Activities,        1. Nonrecourse loans outstanding at                            4. If you are not an S corporation 
earlier. However, (a) does not apply to      the effective date used to finance the                       shareholder, also include liens and 
amounts borrowed by a corporation            activity, to acquire property used in the                    encumbrances on property you 
from a person whose only interest in the     activity, or to acquire your interest in the                 contributed to the activity that are 
activity is as a shareholder of the          activity, including recourse loans                           included on line 11. If you are an S 
corporation. See Pub. 925 for                changed to nonrecourse loans. Enter                          corporation shareholder, do not include 
definitions. If the activity is described in this amount only if it was included on                       any loans that were assumed by the 
(6) under At-Risk Activities, earlier, you   line 11.                                                     corporation or that were liens or 
can include these amounts.                                                                                encumbrances on property you 
                                             2. Cash, property, or borrowed                               contributed to the corporation if the 
 2. Total losses from years before the       amounts, protected against loss by a                         corporation took the property subject to 
effective date for which there were equal    guarantee, stop-loss agreement, or                           the debt.
or greater amounts not at risk at year       other similar arrangement outstanding 

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Line 15                                       (except you) having such an interest,                                                            If you are not an S corporation 
                                              and (b) the activity is described in (1)                                                         shareholder, enter the total net income 
Amount At Risk                                through (5) (or (6) for amounts borrowed                                                         from the activity since the effective date, 
                                              after May 3, 2004) under At-Risk                                                                 taking into account only those years the 
If you completed Part III of Form 6198        Activities, earlier. However, (a) does not                                                       activity had net income. For years since 
for the prior tax year, check box b and       apply to amounts borrowed by a                                                                   the effective date that the activity had a 
enter the amount from line 19b of the         corporation from a person whose only                                                             net loss, see the instructions for line 18, 
prior year form on this line.                 interest in the activity is as a                                                                 item (5), later.
        Do not enter the amount from          shareholder of the corporation. See                                                              If you are an S corporation 
                                              Pub. 925 for definitions.
!       line 10b of the prior year tax                                                                                                         shareholder, enter your total net income 
CAUTION form. Also, do not include on         2. Cash and the adjusted basis of                                                                from the activity for profit years since the 
this line any amounts that are not at risk.   other property contributed to the activity                                                       effective date. Income from the activity 
                                              since the effective date. Adjusted basis                                                         includes gain recognized under section 
                                              is the basis that would be used to figure                                                        357(c) on contributions of property to 
Line 16                                       the loss if the property was sold                                                                the activity. Include all distributions you 
Increases                                     immediately after you contributed it to                                                          received from the activity as well as your 
                                              the activity. See Pub. 551 for details.                                                          share of the activity's taxable income.
If you completed Part III of Form 6198        If you are an S corporation                                                                      5. Gain recognized on the transfer 
for your prior tax year, check box b and      shareholder and you contributed                                                                  or disposition of all or part of the activity 
enter on this line any increases              property to the corporation subject to a                                                         or of your interest in the activity since 
described in (1) through (9) below that       liability, including a liability you are                                                         the effective date.
occurred since the end of your prior tax      personally required to repay, then you                                                           6. Amounts you included in income 
year.                                         must reduce the total of the adjusted                                                            since the effective date because your 
                                              basis of all the property you contributed                                                        amount at risk was less than zero.
If you completed Part III of your prior       by the total of all liabilities the property 
year form, “since effective date” means       was subject to. This applies whether the                                                         7. All money from outside the 
since the end of your prior tax year.         corporation took the property subject to,                                                        activity used since the effective date to 
                                              or assumed, the liabilities.                                                                     repay loans included on lines 14 and 18. 
                                                                                                                                               If, however, you used your own assets to 
                                              3. Loans for which you are                                                                       repay a nonrecourse debt and you 
Enter your share of amounts such as           personally liable that were used to                                                              included an amount in Increases, 
the following.                                finance the activity, to acquire property                                                        earlier, the amounts included as 
1. Net FMV of property you own (not           used in the activity, or to acquire your                                                         repayments cannot exceed the amount 
used in the activity) that secures            interest in the activity and qualified                                                           by which the balance of the loan at the 
nonrecourse loans that were acquired          nonrecourse financing (defined under                                                             time of repayment exceeds the net FMV 
since the effective date and were used        Qualified Nonrecourse Financing,                                                                 of property you own (not used in the 
to finance the activity, to acquire           earlier). Do not enter amounts included                                                          activity) that secures the debt.
property used in the activity, or to          in (2) above.
                                                                                                                                               8. Percentage depletion deducted in 
acquire your interest in the activity.        4. Total net income from this activity                                                           excess of the adjusted basis of the 
Generally, the net FMV is determined          since the effective date (excess of all                                                          depletable property for the activity since 
when the property is pledged as               items of income received or accrued                                                              the effective date. Use the Line 16 
security for the loan.                        over the allowable deductions). Do not                                                           Worksheet to figure this amount. Be 
Do not enter the net FMV if (a) the           enter any amount less than zero. Do not                                                          sure to include the amount for the 
nonrecourse loan was from a person            include the current year income or                                                               current year.
who has an interest in the activity other     gains.
                                                                                                                                               9. If you are an S corporation 
than as a creditor or who is related 
                                                                                                                                               shareholder, enter the loans you made 
under section 465(b)(3)(C) to a person 

Line 16 Worksheet (Item 8)—Figure Percentage Depletion Deducted in 
Excess of
the Adjusted Basis of Depletable Property                                                                                                      Keep for Your Records
                                                           (c)                                                                                                    (d)
(a)                           (b)             Adjusted basis of depletable property before                                                     Excess percentage depletion 
Year           Percentage depletion deduction           any depletion deduction for                                                            (column (b) minus column (c))
                                                           the year                                                                                         but not less than zero

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

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to your S corporation since the effective    If you are an S corporation                     For loans, enter the amount of 
date. Do not include notes that you have     shareholder and the property is subject     TIP the loan you incurred, not the 
given to the activity that are still         to debt that would be included on line 14       current balance of the loan.
outstanding.                                 (or on this line except for the fact that 
                                             there are liens or encumbrances on the      Line 19b
Line 18                                      property in the activity), reduce the 
                                                                                         Amount At Risk
Decreases                                    basis of the distributed property by the 
                                             amount of the debt.
                                                                                         If the amount on line 19b is zero, you 
If you completed Part III of Form 6198       If you are not an S corporation             may be subject to the recapture rules. 
for your prior tax year, check box b and     shareholder, reduce the adjusted basis      See Pub. 925.
enter on this line any decreases             of property withdrawn by the amount, at 
described in (1) through (8) below that      the time of withdrawal, of any              Part IV—Deductible Loss
occurred since the end of your prior tax     nonrecourse liability to which the 
year.                                        property is subject.                        Line 21
                                             Do not include any money from the           Deductible Loss
 If you completed Part III of your prior     activity used to repay loans described in 
year tax form, “since effective date”        the instructions for line 14 on page 5.     If the loss on line 5 is equal to or less 
means since the end of your prior tax        Include amounts that were withdrawn         than the amount on line 20, report the 
year.                                        and recontributed. Recontributed            items in Part I in full on your return, 
                                             amounts must also be included on            subject to any other limitations such as 
 Enter your share of amounts such as         line 16.                                    the passive activity and capital loss 
the following.                               Partners and S corporation                  limitations. Follow the instructions for 
 1. Cash, property, or borrowed              shareholders who recognize gain on          your tax return.
amounts protected against loss by a          distributions from the partnership or S 
guarantee, stop-loss agreement, or           corporation must include the                If the loss on line 5 is more than the 
other similar arrangement entered into       distributions on line 18. They must also    amount on line 20, you must limit your 
since the effective date. Do not include     take them into account as income from       deductible loss to the amount on
items covered by casualty insurance or       the activity on line 16 unless the gain is  line 20, subject to any other limitations.
insurance against tort liability. Enter this recognized in the current year.             Examples.       (a) If line 5 is a loss of 
amount only if it was included on line 16.   4. Recourse loans (and qualified            $400 and line 20 is $1,000, enter ($400) 
See the instructions at the beginning of     nonrecourse financing) changed to           on line 21. (b) If line 5 is a loss of $1,600 
Part III, earlier, for information on        nonrecourse loans since the effective       and line 20 is $1,200, enter ($1,200) on 
effective dates.                             date.                                       line 21. (c) If line 5 is a loss of $800 and 
 2. Amounts borrowed since the               5. Total losses from this activity          line 20 is zero, enter -0- on line 21.
effective date from a person who has an      deducted since the effective date. Take         When comparing lines 5 and 20, 
interest in the activity other than as a     into account only those years in which      TIP treat the loss on line 5 as a 
creditor or who is related under section     you had a net loss. Do not include              positive number only for 
465(b)(3)(C) to a person (except you)        current year losses or deductions. Also,    purposes of determining the amount to 
having such an interest. However, this       do not include losses or deductions you     enter on line 21.
does not apply to (a) amounts borrowed       could not deduct because of the at-risk 
by a corporation from a person whose         rules.
                                                                                         If the amount on line 21 is made up of 
only interest in the activity is as a                 Your prior tax year line 21        only one deduction or loss item, report 
shareholder of the corporation, or (b)       !        deductible loss reduces your       on your return the amount shown on 
amounts borrowed after May 3, 2004,          CAUTION  at-risk investment as of the       line 21, subject to any other limitations. 
and secured by real property used in the     beginning of your current tax year.         Follow the instructions for your tax return 
activity of holding real property (other                                                 to determine where to report the amount 
than mineral property) that, if              6. Nonrecourse liabilities of property      on your return.
nonrecourse, would be qualified              you contributed to the activity since the 
nonrecourse financing. Enter these           effective date.                             If the amount on line 21 is made up of 
amounts only if they were included on        7. Any other at-risk amounts                more than one deduction or loss item in 
line 16 and not included under (1)           included on line 15 that changed to         Part I (such as a Schedule C loss and a 
above. This applies to activities            amounts that are not at risk since the      Schedule D loss), a portion of each 
described in (1) through (5) (or (6) for     effective date.                             such deduction or loss item is allowed 
amounts borrowed after May 3, 2004)                                                      (subject to other limitations) for the year. 
under At-Risk Activities, earlier. See the   8. If you are an S corporation 
instructions at the beginning of Part III,   shareholder, do not include any loans       Determine this portion by multiplying the 
earlier, for information on effective        that were assumed by the corporation or     loss on line 21 by a fraction. Figure the 
dates.                                       that were liens or encumbrances on          fraction by dividing each item of 
                                             property you contributed to the             deduction or loss from the activity by the 
 3. Cash and the adjusted basis of           corporation since the effective date if the total loss from the activity on line 5. The 
other property withdrawn or distributed      corporation took the property subject to    remaining portion of each deduction or 
since the effective date. Adjusted basis     the debt.                                   loss item from the activity is disallowed 
is the basis that would be used to figure                                                and must be carried over to next year.
the loss if the property was sold by the 
activity at the time you withdrew it or it                                               Paperwork Reduction Act Notice. 
was distributed to you.                                                                  We ask for the information on this form 

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to carry out the Internal Revenue laws of   information are confidential, as required     If you have comments concerning the 
the United States. You are required to      by section 6103.                              accuracy of these time estimates or 
give us the information. We need it to      The time needed to complete and file          suggestions for making this form 
ensure that you are complying with          this form will vary depending on              simpler, we would be happy to hear from 
these laws and to allow us to figure and    individual circumstances. The estimated       you. See the instructions for the tax 
collect the right amount of tax.            burden for individual taxpayers filing this   return with which this form is filed.
You are not required to provide the         form is approved under OMB control 
information requested on a form that is     number 1545-0074 and is included in 
subject to the Paperwork Reduction Act      the estimates shown in the instructions 
unless the form displays a valid OMB        for their individual income tax return. 
control number. Books or records            The estimated burden for all other 
relating to a form or its instructions must taxpayers who file this form is shown 
be retained as long as their contents       below.
may become material in the 
administration of any Internal Revenue      Recordkeeping. . . . . . .      1 hr., 12 min.
law. Generally, tax returns and return      Learning about the law 
                                            or the form. . . . . . . . . .     1 hr.
                                            Preparing the form. . . .       1 hr., 25 min.
                                            Copying, assembling, 
                                            and sending the form 
                                            to the IRS. . . . . . . . . . .  20 min.

                                                                                                                                9






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