Four individuals formed Triangle Properties as a C corporation in 2008. The corporation is domiciled in North Carolina. The corporation invested in commercial rental properties that generated passive-activity losses. The shareholders made a Subchapter S election for Triangle Properties effective on January 1, 2014. On the date of conversion, Triangle Properties had $ 118,000 of suspended passive-activity losses from its commercial rental properties. In 2014, the properties generated $ 44,000 of net rental income. Can Triangle Properties carry forward and deduct the suspended passive losses incurred when it was a C corporation against the passive rental income earned while it was an S corporation?
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