I recommend homing in on what MOST vacationers are looking for in a specific market and try to find properties that have natural features/amenities that are scarce.  

Now they want to put the properties into RE Gain Fund, LLC UpREIT (which appears to have been established in 2023). 

It counteracts human nature, which is laziness, greediness, self-centeredness.

Functionally, it operates as a 2-story home since the downstairs area has multiple windows in each room and plenty of natural light.

I am guessing they probably raised $15-25M from investors for the deal, so while the bank would still be covered investors would appear to collect maybe 10-20 cents on the dollar if they were to liquidate.if that's the case then I don't see buying one year really does anything unless I am missing something ? 

Subject To isn't by it's nature fraudulent, it's just the hammer the attorney will use to try to win his case.

This method is helpful if there are time constraints on obtaining a cost segregation study, but it is not the most accurate.SAMPLING OR MODELING APPROACHIn this approach, a cost segregation study is performed over a sample of a large portfolio of properties that are very similar in terms of appearance, use and construction.

I know her prediction doesn't state today, but for activity to jump in February and then again in May to June that doesn't appear to be in a common volume trend of a "normal" year if that exists anymore!

It appears they are posting updates at https://www.fincen.gov/boi

These costs for most of the individuals are considered personal in nature (unless you have a RE portfolio that is run like a business; see below).