Some salesman use that tactic to sell panels.  I think most tax preparers will just say "no".  In my opinion there are definitely circumstances that it can qualify as a business, but the "Net Metering" agreement significantly reduces that chance.  "Net Metering" means the taxpayer is personally using the energy, then sells any "extra" that they may have.

*IF* they treat it as a business, then ALL of the electricity produced would be income (not just the 'net') and whenever the business becomes profitable it will be subject to SE tax.