Thank you for your answer. Based on that information, it sounds like either the accountant who did my 2019 tax did something that was not permissible under TCJA, or I didn't understand what he was doing and thus did not explain it well in my question & comments. I do know and see that the amount in that 2019 'Non-passive loss allowed' field exactly matches the 12% portion of the utilities that he was given.
I'll get with my S-Corp partner and determine which of the TCJA-friendly ways we need to do this. Thanks.
