As conceded via the IRS in CCA 201427016, this argument is incorrect. The aggregation election applies only after a taxpayer has experienced being a real estate Qualified, and just for the purpose of measuring materials participation during the qualifying real estate Expert's rental pursuits. This will make it much easier https://legal-issues-in-commercia77665.tribunablog.com/what-does-real-estate-lawyers-in-windsor-ontario-mean-44979218