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Pursuant to the instructions in IRS Publication 4681 income reported on form 1099-C from debt forgiveness is reported on line 3 of schedule E if the debt has to do with non-farm rental real estate. This is the same line you use for rental income. So I believe the answer is that it would be considered passive income from rental real estate absent an election to be considered a real estate professional under IRC 469(c)(7).

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Q: Is a 1099-C debt forgiven from a real estate short sale taxed and considered as earned income or passive income due to it being Real Estate Rental loss?
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