Although the first major curbs on deductibility of passive activity losses and credits were enacted in 1986 as part of the Tax Reform Act of 1986,1 the rules on “recharacterizations” were not enacted until 1987 in the Revenue Act of 19872 which gave authority to the Secretary of the Treasury to prescribe regulations “. . . requiring net income or gain from a limited partnership or other passive activity to be treated as not from a passive activity.”3 Those regulations were adopted in 1992.4 The “recharacterization” rules are outlined in the regulations.