Taxpayer owns a hotel and a construction company in different parts of the state. It would be helpful to aggregate these businesses for 199A.
Sec. 1.199A-4(b)(1)(v) talks about meeting 2 of the following 3 factors that demonstrates the businesses are integrated.
1) provides products / services that the same or often provided together
2) share facilities or significant centralized business elements
3) operated in coordination with, or reliance on, each other
Taxpayer can pass # 2, but # 1 and # 3 seem like a stretch. How loosely do you think we can apply this test?