I have a client who owns a "seasonal' transient rental (residence held in a Trust).  He rents for 3 months in summer and closes the house for the rest of the year.  There is no personal use so vacation home rules do not apply (and this year his average rental days were 7.8)  I've narrowed down our tax reporting choices to: 1) Make rental available all year - deduct all expenses and take depreciation for full year.  2) Only report activity related to the period available for rental (all income, expenses incurred during rental period and prorated expenses for property taxes, insurance...). 

For option 1 the rental needs to be advertised and available - this is questionable as he uses a local real estate agent who "advertises" via word of mouth and only makes it available for the summer months.  So would have a hard time proving it was advertised for a full year rental.  If we are stuck with option 2, can he take depreciation for the three months it is available for rent?  I believe he would be putting the residence "in and out of service" each year and it looks like deprecation may not be allowed (?) - though I've seen reference to "permanent" removal from service where this is only temporary removal.  It appears that the IRS does not provide much guidance in this area where there is no personal use for a seasonal rental.  Any suggestions would be greatly appreciated!