This was more prevalent in the go-go days prior to 2008, but it still goes on today as well.There are actually, 8 or 9 criteria that the IRS uses to determine who is a dealer and there is case law on the subject going back to the 1960s, so a simple answer may not be the correct answer.If you contemplate doing development, you should have on your team a land development attorney as well as a CPA versed in dealer issues.