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@BenT9 wrote:

I would think that if an LLC is treated as a partnership for tax purposes electing out would be permitted no matter what name the property is held in. 


Yes, but it is not; sort of akin to why a partnership with only two partners who are married to each other can elect qualified joint venture (QJV) status but a married couple who are the only members of an LLC cannot (unless they reside in a community property state).