Some custodians like Equity Trust do not like that the LLC model erodes their fees and not only will not support this, but actively promote the idea that the IRA LLC is a recipe for trouble with the IRS - which it absolutely is not if used properly.When it comes to determining the active business vs passive investment distinction, and therefore potential exposure to UBTI, there is no hard and fast rule.  

After that 3 day audit I had back in early 2012 over my 2009&2010 returns they nailed me for SE taxes & disallowed legit well documented mileage etc.They sure make you feel guilty going in & after I cut the check for the extra owed plus penalties I got the distinct feeling they were going to audit me every year thereafter.BUT I just got notified that I over paid my taxes for those same years ??????

Do what's right for you.Also, I get the distinct impression that the seller may just be a manipulative person, not necessarily inclined to sell, but she is simply getting her jollies. 

I believe there is a distinction (I'm viewed by the IRS as a "real estate professional")I think I may short sell an investment property I own in CA and expect to sell it for 60K-70K less than what I owe.

Another distinction is that the Zillow API is not the same data that you will get on Zillow. 

There is a very sharp distinction and you should make very certain of how your purchase was structured to prevent problems.To the best of my knowledge, an LLC can own another LLC.

It is an important distinction because there is a substantial difference in how 5+ unit properties are priced and financed versus the 'plexes' which are much more similar to single family residential (sfr).Happy to discuss and go into as much detail as you need on multifamily (5+ units) being an apartment guy at heart.Good hunting-

But there is one distinct difference between the two that's central to this discussion and I've mentioned it above - the pool of buyers.

you have some distinct advantages over many others..

In seriousness, I think you draw a needed distinction that is not absent of any of the other posts.