The IRS Chief Counsel's Office, in a memo, discussed whether a real estate agent who is not licensed as a real estate broker can be engaged in a real property brokerage trade or business for purposes of the real estate professional rule contained in I.R.C. Sec. 469(c)(7). The IRS determined that the agent could be engaged in a real property brokerage business because he brought together buyers and sellers of real estate. Conversely, the IRS determined that a mortgage broker of financial instruments is not in a real property brokerage trade or business as defined by I.R.C. Sec. 469(c)(7)(C). C.C.M. 201504010 (Dec. 17, 2014).