Tax Professionals; how are you guiding your clients R.E. phantom income?

[Ari Newman]

A question to all the tax pros; how are you guiding your clients when their R.E. activity has the potential to generate phantom income?  

I'm seeing lots of Gurus promoting and teaching about buying Sub-2 and then selling on a wrap.  Other past promoters sold a similar strategy by wrapping contract for deed, installment sale, Lonnie Deals (personal property), etc.  Clearly, there was never any intention to hold these assets for investments.  It would be hard not chuckle during an audit when buying/selling so quickly in volume is clearly dealer activity.  So someone, please clarify what am I missing?  I'm not talking about the entities that buy/sell one or two deals and year but rather those that use these methods as their business model thinking they are eligible for installment sales treatment.