wow! guess i blew the composition of my question.  let me try again.

The S corp owns this property.  My client is 100% shareholder of the S Corp.

I'm very intimate with S Corps.  my question is related to the activity of renting real estate being active or passive in the following circumstance.

The property was used for other things in past but was idle, so my client decided to try renting it through air b&B.

he makes all management decisions and does almost all hands-on work toward it's maintenance.

altho renting real estate is generally a passive activity, i have been led to believe that my client's active and material participation in it allows the activity to be 'recharacterized' as nonpassive.

maybe the question should be passive vs nonpassive rather than passive vs active.  my bad.

and no, he provides no services to the renters.  he's an attny.