As conceded because of the IRS in CCA 201427016, this argument is incorrect. The aggregation election applies only following a taxpayer has competent being a real estate Experienced, and only for the goal of measuring materials participation while in the qualifying real estate Expert's rental pursuits. B complains, of course, https://elliottnbmvg.isblog.net/not-known-facts-about-understanding-real-estate-law-47826512