SECTION 3. SCOPE

This revenue procedure applies to all taxpayers to which the rules in § 1.469–4 apply. Special rules apply for groupings by partnerships and S corporations and are described in section 4.05 of this revenue procedure. This revenue procedure does not apply to the rental real estate activities (as defined in § 1.469–9(b)(3)) of a taxpayer in a year in which the taxpayer is a qualifying taxpayer (as defined in § 1.469–9(b)(6)) if it has made the election provided for in § 1.469–9(g).