@Carl wrote:
....As I understand the post and interpret the IRS pub, they don't qualify as an RE professional. Therefore, the material participation rules are relevant.
Why are they relevant? Put differently, for what purpose since we are addressing the passive activity loss rules? I really do not believe you have a good grasp of Section 469, in relevant part.
Unless the taxpayer first qualifies as a real estate professional (personal services totaling more than 50% and more than 750 hours), you do not need to determine whether the taxpayer materially participates in the rental activity for the purposes of treating rental activity losses as nonpassive.
