If you PM me I can give you my interpretation of it, but that isn't legal advice.

@Jade Smith under your proposal, you would probably need an agent license to work with a broker.Hopefully, you have a copy of the regulations that allow your interpretation of California licensing requirements and didn't depend on someone's opinion:)

You've confirmed what I'd interpreted in my research.  

But as I read the highlighted sections above, I'm seeing two different interpretations; 1) anyone that has a right to the property and was not notified [33.54(b)] is not bound by ANY limitations period, 2) anyone that falls into the first interpretation actually has a 2 year limitation [34.08(c)].

I will forewarn you they are written in a lot of legal language, so it can be difficult to interpret. 

Even CPAs and lawyers struggle to interpret it.

Please keep in mind this is a very conservative interpretation of the law here (section 469).

The key is in the interpretation of the passive income rules and guidelines which define what is a REP (real estate professional), as it relates to this space.I am looking for:1.

The way we interpret it (based on the tax court cases) to make it more black and white: Any hour that is material participation must be integral to the rental, AKA must directly affect the profit and loss of the property.

Sounds like they are having a wrong interpretation of active/passive.