IRS Form 8594

I acquired a mobile home park in December 2024. All of the homes are tenant owned. I own the land, the utilities and laundry room with equipment. Do I need to file IRS form 8594? I have had various CPAs provide differing points of view. One said no as I acquired a “single property”, and Form 8594 is geared for asset acquisitions that essentially acquire the assets of a trade or business in which goodwill or other Section 197 intangible assets could be a part of the transaction. My purchase agreement didn’t allocate any of the purchase price to anything. I have a cost segregation study in the works, and it seems to me that if I cost seg on my tax returns, then it’s not a “single asset”.

 

As this is considered commercial real estate investment, does that count as a “trade or business” or is it an investment? As my spouse is a “RE professional”, this will not be considered passive income.