The way I read §1.266-1, only certain things qualify for that election, and most property would not qualify (at least under §266).
(1) Land ("unimproved and unproductive real property").
(2) Property under construction (" real property, whether improved or unimproved and whether productive or unproductive ... paid or incurred for the development of the real property or for the construction of an improvement or additional improvement to such real property").
(3) Non-real estate under certain conditions ("personal property").
(4) Other things that the "Commissioner" thinks is allowable.
<a rel="nofollow" target="_blank" href="
https://www.law.cornell.edu/cfr/text/26/1.266-1">https://www.law.cornell.edu/cfr/text/26/1.266-1</a>
