skojima
Level 2
Sorry guys been down with the flu.  Of all times.  I did speak to Lacerte technical and it was not very informative.  Regarding the separate safe harbor elections, technical said that that is a tax issue that he was not supposed to comment on.  He did say that for aggregated properties he believed that one safe harbor should be made but he could not tell me how to do this since Lacerete was creating three separate safe harbor statements.  So I prepared a safe harbor statement indicating my client's three properties and had client sign and attached as a PDF.  Since the safe harbor came out in 2019 it can be used for 2018 if you are to follow Notice 2019-7.  I believe that confirmation from client that they can meet the 250 hours requirement should be obtained or least discussed with client since they are signing under penalty of perjury.
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