The regulations provide that if a qualified opportunity fund (QOF) or qualified opportunity zone business (QOZB) holds parcels of real property inside and outside an opportunity zone (OZ), then both parcels will be deemed to be located in an OZ if (i) both parcels are used in the QOF's or QOZB's business activities, (ii) the parcels are contiguous (you can ignore the road) and (iii) either the square footage or unadjusted cost basis of the parcel in the OZ is greater than the square footage or unadjusted cost basis, respectively, of the parcel outside the OZ. So in your case an answer depends on the relative sizes of the parcels.
