Alice owns 100 percent of Medical Data, a C corporation, and 100 percent of Your Realtors, an S corporation. She worked full time for Medical Data (i.e., she materially participated in the entity), but Alice did not materially participate in Your Realtors. During the tax years 2014 through 2016, Your Realtors leased real estate to Medical Data.

Alice reported these rental amounts as passive activity income on her Schedule E, and she offset that income against passive activity losses from other entities. The IRS reclassified this rental income as nonpassive income under Reg. § 1.469–2(f)(6). Who is right? Does § 469 apply to S corporations? Elaborate.