real estate 750 hours

G I G O maybe?

Are you referring to real estate professional status?

What's your cite for "According to IRS "?

Does the taxpayer qualify as a Real Estate Professional who Materially Participates in the rental?

If yes, your client should be able to prove it, and the IRS will allow all losses.

If the taxpayer does not qualify, the loss will be limited to $25,000 (or less, depending on MAGI and Active Participation).

This is like saying "according to the police, going 30mph in a school zone is illegal."  The police are just there to enforce the law that was passed by elected representatives.  Congress enacted, and the President signed Internal Revenue Code Section 469.  That's where the 750-hour requirement came from.  Don't blame IRS, they are just enforcing it.  Or do you think laws are meant to be broken?

It was over 15 years ago, but I was helping another CPA with his client's claim for Real Estate Professional(REP) status.

The taxpayer had over 20 rental properties, spent nearly every day working on them and driving back and forth, many over 100 miles away. He gave us a meticulous spreadsheet with days and miles, for every day, including Xmas and NY's. (!) Really?! Much, much more than 750 hours in a calendar year.

Many, many hours. He even had a full time job besides the rentals. 

The agent threw out many of those so-called working days, but still had much more than 750 hours; however, there is also the more than 50% test, too. With a full time job besides, the 50% tax would have been problematic.

Fortunately, he only worked 4 days a week for part of the year, and then he was work-disabled for another part of the year(only disabled enough to not be required nor allowed to work at the job), so that brought the total hours worked down and the REP hours up above the >50% test.

The agent flunked him anyway, and that's the last I heard about it.

ps I loved IRC Section 469. Made a career out of it. I could have written a manual about it and taught about it. (Oh, wait, I did!)