Regardless of whether or how an item of income, gain, loss, deduction, or credit is characterized for federal income tax purposes, that item of income, gain, loss, deduction, or credit is from the same source and incurred in the same manner for a pass-through entity taxpayer as if the item of income, gain, loss, deduction, or credit is: (1) realized directly from the source from which the item of income, gain, loss, deduction, or credit is realized by the pass-through entity; or (2) incurred in the same manner as incurred by the pass-through entity.
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