Thats why I use the word "typically" when referring to this stuff. 🙂
I myself have one rental (of three) that I do show a gain on. That's because I paid off that particular rental property years ago. With no mortgage interest to deduct on it after that, it did take a few years to use up the carry over losses. I've been showing a gain on that particular property for a few years now. But the bottom line on the SCH E still shows a loss because of the other two rentals. That loss is less than $25K and I have the "other" ordinary income to deduct it from. So I've not had any carryovers for quite a bit now.
