Comparing working as a W2 employee doesn't really compare to working as a contractor. Getting to choose your own hours, the direction of your project, who you get to work with, etc. is far more valuable to me than a bit more money.
So he is nearly there, but not yet.
I think you're confusing it with personal projects.
There is nuance in that statement. The IRS has a test for whether a person is an employee or a contractor.
https://www.irs.gov/newsroom/understanding-employee-vs-contr...