Not sure if I agree. It is not crystal clear, however, but I would lean toward Sec 195 applying to rental properties. One, rental properties can rise to the level of a TorB for various purposes - RE professional status and Sec 199A for example. Even if it doesn't rise to that level or you disagree that it can for Sec 195 purposes, the capitalization and deduction rules for startup activities also apply to Sec. 212 activities. Sec. 212 activities are those conducted for the production of income as opposed to trade or business activities.
https://www.thetaxadviser.com/issues/2017/sep/deducting-startup-expansion-costs.html
