Investors & landlords

Using https://apps.irs.gov/app/picklist/list/priorFormPublication.html;jsessionid=qEm0ZREGp-ExtdzAEhkvlcSn..., I looked up the 2012 instructions for Form 1099-MISC, and I could not find the wording you referred to.  This is also a very dated reference, hardly anything authoritative 10 years later.   Do you have any better support for this position?  You may get laughed out of Tax Court if you relied on this.