For the quickness in response: (I have all the same access to documents and google as the next guy, I may be slightly off in my interpretation but you will get the point) - Modular are made in a factory and brought to the site on wheels and a modular frame.

There is enough grey area in the IRS rules that often you leave yourself open to an interpretation by an individual IRS agent, rather than by some code your CPA can point to then cry "FOUL!"

A statute changed in 2009 that might have resulted in that interpretation. 

Hopefully a CPA can confirm as I am not an expert in interpreting IRS rules.

You also mentioned your plan, past tense as it seems you have already begun "working" your plan.You have received comments, well founded, and have rebutted each pulling definitions (excerpts of complete definitions) as your basis for arguing against those comments in favor of your interpretations.

I agree with Bill's interpretation of the forms, but these are state specific.

When people ask me what I do for work, I give them an honest personal interpretation of what exactly it is that I do.

No matter what you write in the letter I would always interpret it as "I want your house and I want it cheap.

@Jimmy Nguyen construction money , interprets only , you will pay monthly. $100k @6% = $500/month. 20% is the min project return. $500k arv x 20% = $100k return potential 

Bigger Pockets is not the place for legal matters or interpretations of laws.