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@sjrcpa wrote:

Maybe 8 is an efile limit?

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Yes, the IRS e-file system is limited to 8 schedule Cs (well, at least it used to be ... I haven't checked the last couple of years).

So if there are more than eight Schedule Cs, it would need to be paper-filed.

Unless there are several Qualified Joint Ventures (two Schedule Cs per business), more than eight seems quite excessive.  You and the client may want to analyze things to see if any activities really should be combined into a business, if any activities really are a hobby, or if everything may want to be restructured (possibly looking into being taxed as a corporation).