An activity that constitutes a rental for purposes of the passive loss rules is always passive regardless of the taxpayer's participation except when the exception for real estate developers applies.

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This statement is true. According to the passive loss rules, an activity is considered rental if it involves the use of tangible property and the payment of rental expenses. Such rental activities are generally considered passive, regardless of the taxpayer's level of participation, unless they qualify for certain exceptions (such as the exception for real estate developers).

An Activity That Constitutes a Rental for Purposes of the Passive