If it's a shouting match between your attorney and the Qi it would almost have to be some kind of entity/tax-payer match issue. 

(Those guys seem like the experts in this domain.)On a side note, this is a great example of the sort of issue ChatGPT can help you think through.Here for example is its summary conclusion when I ask it about this issue and then also ask if using a Section 179 election or Section 168(k) bonus depreciation provide workarounds:Even though §263(a) safe harbor isn’t available pre–business start, the taxpayer still gets the lion’s share of the deduction in the startup year via §179 and §168(k), assuming:The short-term rental qualifies as a Section 162 trade or business,The property is placed in service during the tax year, andThe taxpayer has enough trade/business income to absorb the §179 deduction (or is okay carrying it forward).BTW the full analysis ChatGPT provides when you ask it about this is actually quite lengthy with numerous cites to the relevant regulations, statutes and court decisions.

Since I hold these in my IRA (which is low on funds after this years tax payments) I'm trying to figure out the most cost effect way to do it as attorneys want $2200 and up for each property.

However, we will classify these specific to what the taxpayer decides and can change it if necessary.

They’d rather mooch off taxpayers or their parents.Still, many men who don’t go to college also don’t want to work in factories or other blue-collar occupations, perhaps because they don’t believe there’s dignity in such jobs.

If Trump RETURNS our tax payment's that were recaptured for whatever BS spending attempts, he's a bad guy. 

But the delayed Capital gain tax payment for 15 years was great.  

That seems like such a talent to waste especially since it probably took a lot of time and money to achieve - either paid for by his parents, or perhaps subsidized by the taxpayers because we need talented people in society. 

And if your LLC currently is disregarded (meaning it does not file it's own tax return and all activity of the property is reported on your personal return) then you are the real tax payer.

I use the term "free-loading" but I'm sure your tenant is 100% incapable of supporting herself and deserves to be supported by the taxpayers for life.