Curt, how is your business model of flipping DW mobile homes via "rent to own" any different as a practical matter than the straight seller financing model that Mitch Stephens is touting? (Assuming you are still doing that)
I can tell you the IRS is wise to the "rent to own" thing and will treat it exactly the same as a straight seller finance, unless you do it exactly right (which takes away all of the traditional financial benefits of lease optioning).
So will Dodd Frank.
Even holding for 1 year then selling will not get around the installment sales rule if the IRS can show in tax court that your INTENT was to circumvent the law to avoid dealer status.
If you are still selling your dw on land deals on rent to own, where are you finding the funding to pull your cash out of the deal to reinvest in the next property (i.e. "BRRRR")? I cannot find ANYONE that wants to finance or cash out refi on investor mobile home deals.
It's really quite ridiculous, actually.