My question too.  Same scenario, he also keeps separate records in Quicken, etc.  Issues 1099s to all vendors when required.  Also new idea, since managing these condos which have HOA assessments, are we allowed to drill down to the HOA dues and carve out wages, time, and assets that are utilized by the HOA managers on the landlord's behalf?  With no bright line test, only facts and circumstances if not meeting the safe harbor 250 hours, do we have any guidance for the mom and pop landlords?