At risk rules are statutory limitations of a taxpayer's deductible losses to the amount the taxpayer could actually lose, to prevent the taxpayer from sheltering income. For example, 26 U.S.C.S. § 465(a)(1) provides that in the case of individuals engaged in certain activities, including equipment leasing, any loss from such activity for the taxable year shall be allowed only to the extent to which the taxpayer is "at risk" for such activity at the close of the taxable year. Losses disallowed by this provision are carried forward and allowed as losses in succeeding taxable years if the at-risk rules become satisfied. A taxpayer is "at risk" for the amount of money and the adjusted basis of other property contributed by the taxpayer to the activity.