While this forum is not conducive to getting all the facts required for a question of this nature, I will venture to say "no" as I don't believe you can meet the following requirement (which is one of five that must be met):
- The trades or businesses to be aggregated satisfy at least two of the following factors (based on all of the facts and circumstances):
- The trades or businesses provide products, property, or services that are the same or customarily offered together;
- The trades or businesses share facilities or share significant centralized business elements, such as personnel, accounting, legal, manufacturing, purchasing, human resources, or information technology;
- The trades or businesses are operated in coordination with, or reliance upon, one or more of the businesses in the aggregated group (for example, supply chain interdependencies).
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
