Did someone else do this client's return before you?

Interesting.  The client exchanged into a DST in 2022 and the DST did a cost seg study that did not list land.  So, yes, it is possible that the cost seg provider wasn't provided info about purchased land but I don't have those tax returns.

The client thinks the land is leased to the DST by an unrelated party.

The client received 19 DSTs!  Seven of the DSTs did a cost seg study in 2022 and the end result for my client is 1.2 million in available bonus depreciation. This results in a NOL carryover of 1M. 

I'm thinking of the election to opt out of bonus depreciation for "smoother" future income and to avoid IRS scrutiny, which is a fear not based on much data. (CCH Answerconnect research service lists 9 tax cases from 1996 to 2021 in which cost segregations studies were cited.)