Sometimes. The regulations that define material participation (Treas. Reg. §1.469-5T) say nothing specific about travel, and the Tax Court has gone both ways: it has accepted travel between properties by an owner who was plainly running them, and it has struck travel that looked like commuting to an investment. There is no percentage rule and no safe harbor. The practical answer is to log travel separately from the work you did on arrival, so a challenge to the drive does not take the work down with it.
Why the question is unsettled
The regulation defines participation as work done in connection with an activity in which you own an interest, then carves out two things: work done in your capacity as an investor, and work not customarily done by owners if a main purpose is to avoid the passive-loss rules. Travel fits neatly into neither box. Driving to fix a water heater is not investing, but it is also not fixing the water heater.
Because the text is silent, the outcome turns on facts: why you went, what you did when you got there, and whether the record makes both of those obvious. That is why two owners with identical mileage can get different answers.
Where courts have said no
The pattern in the cases that disallowed travel is that the trip looked like a commute or a visit rather than an operational task. In Truskowsky (T.C. Summ. Op. 2003-130) and Trzeciak (T.C. Memo 2012-83), time spent getting to properties did not help the taxpayers reach the hours they needed, because the court was not persuaded the travel itself was participation in the rental activity as opposed to the ordinary cost of owning something at a distance.
The lesson is not "travel never counts." It is that undifferentiated travel — a block of hours labelled "drove to the cabin" with nothing about purpose — gives a court nothing to hold on to.
Where a court said yes
In Leyh (T.C. Summ. Op. 2015-27), the taxpayer managed multiple rental properties personally, kept a log, and restated it during the examination with more detail. The court accepted a substantial number of hours, including travel between the properties, because the travel was tied to specific management work at each stop and the overall record was credible. The travel counted as part of the work, not instead of it.
The distinguishing facts are worth listing plainly: hands-on management, trips with a stated operational purpose, and corroboration for what happened at the destination.
A working rule
Many practitioners use a three-part test before counting a trip:
- Purpose. The trip was made to do operational work — a turnover, a repair, a walkthrough with a contractor, a supply delivery — not to look at the property or to be nearby.
- Destination work. Something logged happened at the other end, with its own entry and its own duration.
- Corroboration. Something outside your memory supports the trip: a fuel or toll receipt, an odometer note, a hardware-store receipt dated that day, a guest message saying the lock was fixed.
If a trip fails any of the three, it is still worth logging — just do not rely on it. Which brings us to how to write it down.
How to log a trip so it survives
The mistake owners make is folding the drive into the job: "Fixed the deck, 6 hours," where two of those hours were on the highway. If the travel is later challenged, the whole entry becomes suspect. Split it:
| Entry | Example |
|---|---|
| Travel out | 2026-08-09 · Lakeview cabin · Travel from home to property for deck repair · 1h 05m · odometer 41,230–41,288 |
| Work | 2026-08-09 · Lakeview cabin · Replaced four rotted deck boards, sealed · 3h 20m · lumber receipt, before/after photos |
| Travel back | 2026-08-09 · Lakeview cabin · Return travel · 1h 10m |
Now a CPA can present the 3h 20m with confidence and argue the 2h 15m of travel separately. If the travel is disallowed, the repair stands. STR Tracker has an activity category for travel on each entry for exactly this reason, so the export can show hours with and without travel in one report.
Three details that make travel entries credible:
- Purpose in the description, not just "travel." "Travel to property for deck repair" ties the drive to the work entry that follows.
- Actual duration, not round numbers. A 1h 05m entry from a maps estimate reads as honest; "1 hour" every time reads as reconstructed.
- A reason it had to be you. If a cleaner could have let the plumber in, say why you went instead — you inspected the work, you carried the parts, you met the guest.
Out-of-state owners: flights and the "why did you go" test
Owners who fly to a property face the same question with higher stakes, because a two-day trip can be twenty hours of travel against a few hours of work. The record needs to show that the trip was scheduled around operational tasks: a list of what was done each day, receipts from the trip, photos, contractor meetings with names and times.
Trips that combine a stay at the property with work are the hardest case. Personal use of the property has its own consequences under the tax rules, and mixing personal days with logged hours invites the argument that the trip was a vacation with chores. Keep the days you used the property personally out of the hours log entirely, and log the work days with the same specificity as any other entry. Then let a tax professional decide how much of the travel to claim. See the guide on what counts as participation for the underlying rules.
The 750-hour test raises the stakes
For owners pursuing real estate professional status rather than the short-term rental exception, travel is a bigger share of the total and a bigger target. The 750-hour test under §469(c)(7) also requires that more than half of all personal services be in real property trades or businesses, so inflated travel hours can distort both prongs. The 750-hour test guide covers the mechanics; the record-keeping advice here applies with more force, not less.
What to do this week
Look back at your last three trips to the property. If any of them is logged as a single block, split it into travel and work entries from whatever evidence you still have — the maps history on your phone, the receipts, the photos. Mark the split entries as reconstructed. From the next trip on, log the drive as its own line before you get out of the car.
If you are not logging yet, the free spreadsheet template has the columns, or you can start a free trial and log from your phone. Whichever you use, the question to answer on every travel entry is the one an examiner will ask: what did you go there to do, and what shows you did it?