The part I found fascinating is that the RA, citing some unspecified Appeals precedent, allowed his yacht activities as business activities, despite minimal income!

In retail, while I have minimal direct experience lately, I was talking with some lenders about a month or two ago, as I was looking at buying a strip center myself.  

Investors are also looking for advice on building their entire portfolio instead of people pitching one deal at a time. 

Investing in syndications, passively with an unrelated party (beware of UBIT if an IRA on both of those), or just hard money loans to third parties are all great ways to invest in real estate with a retirement account to minimize as many headaches as possible.

I was forced to cash out my 401k in payments to minimize tax penalties, using it to complete house projects and pay off some debt.

Some may have minimal rental periods.  90 days is fairly common.   

If your knowledge of construction is low, you'd otherwise be relying on the GC to do everything correct w/ a reasonable level of quality (inspectors just look for minimal code compliance).   

But with showing minimal taxable income over the last 2 years, it's now hard to qualify for any type of traditional bank refinancing.

@Sean Ross  Yes, if outside of CA minimal management. 

#1 What's missing is Profitability.....Pretty weird....I think both are either losing money or just barely hanging on to minimal profits.