The ROBS structure might be helpful in creating income for you if you have significant retirement savings already, but it is usually complex and expensive compared to other options.

Like mobile home parks, syndication, STRs, apartment complexes, storage facilities, note investing, and on and on.

Now we can refer to some new developments (example link below) and respond, "you can sue the court to reopen!"

I would love get into smaller apartment complexes as well! 

https://www.biggerpockets.com/member-blogs/9278/61605-real-estate-investor-vs-dealerWhen analyzing the Winthrop factors, most people, including @Simon Filip who wrote the above quoted blog, fail to mention the context of that famous court case.

I have found some additional information - a helpful clerk in the court office pointed out where I could find the filing.  

If I don’t hear from you in the next 10 minutes, I will assume you aren’t attending and I will move on to my next appointment.Using this system as dramatically reduced any wasted time I used to endure as part of the showing process as well as giving me data about their timeliness/responsiveness/respect for others' time.At the showing, I collect their completed application (sent via PDF prior or filled out on premises), scan their photo ID and last 2 pay stubs.Then, I do some digging around online (social media, court records, Google) and if it looks like they are representing themselves to me accurately, I contact them to set up a "contract to hold" meeting - usually the day after the showing since qualified applicants need to be "closed" ASAP.

I know of entire large apartment complexes that have not a single section 8 tenant.

You got cash for an increase in debt.There may be debt-financed distribution concerns but that is another story.Regarding your structure - a little complex but if you keep the proper books among all the entities...sure...

I'm unsure how to measure the benefit of such high cash flow vs. the risk of being unable to get rid of the smoke or the industrial complex ruining property values.