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@LSTAX wrote:

new information on the HELOC - it originated in 2016 as stated but was originally for $125,000 and the entire amount was used in 2019 for the down payment on the new house that is now the tax payer's primary residence.  Thanks for weighing in again.

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That doesn't make sense.  The way you phrased it sounds like they borrowed $125,000 in 2016, it sat in their savings account for 3 years, then spend on the new house.

At any rate, if the borrowed money was not for the rental, it is not a rental expense.  Even if it was used for their new personal home, because the mortgage is not secured by there personal residence, it is not deductible on Schedule A either.