Is interest from private lending passive income?

[Alicia Zhao]

Hi,

I lent some money to 3 people last year as a private lender. I told my tax accountant that it should be considered as passive income to offset the passive loss from my rental property. But my tax accountant said it should be considered as portfolio investment income, not passive income. So we are not in agreement.

I sent this to my tax accountant 

https://www.investopedia.com/terms/p/passiveincome.asp.

She sent the IRS link to me 

https://www.irs.gov/pub/irs-pdf/p925.pdf

I wonder how your tax accountant treat your private lending interest?

Thank you!

Alicia