Partnership buys land in 2022 and starts construction of a car wash. The partnership will lease the real property to an unrelated tenant who will purchase all of the equipment and run the business. The tenant will start paying rent once the C/O has been issued, which is projected to be in the last week of December... but could get delayed. The car wash is not expected to open until sometime in 2023.
Is the C/O the determining factor for the placed-in-service date of the real property or does the car wash need to be operating before for deprecation on the tunnels starts? Any chance PIS for the tunnels could be prior to the C/O date?