199A Mixed use building

[Sashaa]

Any advice on how to separate the Real Estate Enterprise for the 199A Rental Safe Harbor in the following situation?

1 Rental is a Building with multiple units of which is some are Commercial businesses and some are residential apartments. (one set of books & records)

1 Rental is a Room Rental in taxpayer's primary residence. (second set of books & records)

For the aggregation requirement that commercial and residential cannot be combined into one enterprise, yet separate books and records must be kept for each...

[sjrcpa]

Consider whether it is a Qualified Business without resorting to the Safe Harbor.

[Sashaa]

Thank you for that suggestion. 🙂

[Sashaa · Accepted solution]

SOLVED! 

Apparently I missed it the first 20 times I read the safe harbor...

From the second to the last paragraph on page 4 of Rev. Proc. 2019-38

"An interest in mixed-use property may be treated as a single rental real estate enterprise or may be bifurcated into separate residential and commercial interests.  For purposes of this revenue procedure, mixed-use property is defined as a single building that combines residential and commercial units.  An interest in mixed-use property, if treated as a single rental real estate enterprise, may not be treated as part of the same enterprise as other residential, commercial, or mixed-use property."