Maximizing Investor Losses

this is a discussion, just need a couple paragraphs

Maximizing Investor Losses

After reviewing the scenario, compare and contrast the at-risk rules and passive activity limits.  Discuss the purpose for each, and suggest at least two (2) tax-planning strategies for ensuring that the IRS allows passive losses in order to reduce your tax liability.  Provide support for your suggestion.

Imagine that you in the process of creating a new business structure and have to choose between a personal service corporation and one that is closely held.  Consider the tax deductions, at-risk rules, and passive loss limitations, and recommend the type of structure that has the greatest potential to minimize your tax liability.  Defend your positon.