The ruling applies to business property because the question mostly arises with business deals. The issue was settled back in 1953 with the 3rd Circuit decision in Paul, but you can still try the "investment" red herring:

"The law can do many things by the use of fictions, but it would be absurd to say that it can allow a man to acquire a building in 1944 which did not come into existence until 1946. The boast of the law of taxation is that it deals with realities. The least that reality requires here is that we hold that a building cannot be acquired before it exists."

https://law.justia.com/cases/federal/appellate-courts/F2/206/763/27504/