I've included an example below to help illustrate this.So different lenders have different rates (which do vary even for DSCR loans) but these are factors they all consider.See example below:DSCR < 1Principal + Interest = $1,700Taxes = $350, Insurance = $100, Association Dues = $50Total PITIA = $2200Rent = $2000DSCR = Rent/PITIA = 2000/2200 = 0.91Since the DSCR is 0.91, we know the expenses are greater than the income of the property.DSCR >1Principal + Interest = $1,500Taxes = $250, Insurance = $100, Association Dues = $25Total PITIA = $1875 Rent = $2300DSCR = Rent/PITIA = 2300/1875 = 1.23DSCR lenders generally let you vest either individually or as an LLC.

If you live in warmer places this probably isn’tAn issue as much but I’m done with the variable factor of tenants putting the heat on 80 degrees and then leaving windows open when it’s -25 out.

Several other factors as well. 

The real estate professional or coordinator has input and dealmaking influence, but the terms of financing are generally the key component to unlocking the transaction. 

Looking at the totality of these factors, my conclusion was that the "benefits and burdens" test is met on the auction date.Does it contradict the Revenue Ruling you cited?

However, these factors alone may not be sufficient legal grounds to terminate the lease unilaterally.

Most rentals you may not make anything net-net once you factor all things in but after 3-5 years you are usually glad you bought them.

There are a lot of factors at play that are hard to what-if over the internet based on a couple sentences of info.

This includes factors such as interest rates, loan-to-value ratios, and repayment schedules.

From my part, I analyze the property's location, neighborhood growth, appreciation factor, the average rents using some paid tools, and crunch some numbers for them to let them know the CoC return, cash flow, and more etc.