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@TaxGuyBill wrote:

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The old office should amend 2020, 2021 and 2022 for free.  And the old tax office should pay the client for the missed tax savings from 2016-2019.

Unfortunately, Form 3115 does not apply because this was just a "mathematical or posting error".

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I agree with Bill (on all counts).  We don't have the full timeline but it sounds like a permissible method of accounting for depreciation was adopted and then later arbitrarily changed to an impermissible method.

If your client is lucky, the rentals were all operated at a loss and you might be able to just adjust the PAL carryovers to include depreciation.  But any way you slice it, you're looking at hours of time spent across multiple tax years just to ascertain the extent of the damage.

Another alternative is for your client to die so the heirs get a step-up in basis without having to deal with prior "allowed or allowable" depreciation.  I don't recommend this strategy due to the side effects.