100 is enoug, id say
to be more precise, there is a chance that this given guy keeps his mmr the same due to luck, and the higher the amount of games, the lower this chance becomes. after 100 games, it is still possible that it was just an accident, but the chance is, you know, so small that we can just ignore it and say "aight apparently he deserves this 4.1k".
if u r not lazy and studied stata/econometrics/etc., u can run a regression, use confidence intervals/hypothesis testing and find out at which amount of games you can be 95% sure (which is the most common interval) that for given difference between initial mmr and smurf's mmr, you can consider smurf's mmr to be constant due to your plays rather than luck.
Smurf is 4530 mmr and main account is 3.5k down from 3.9k max, smurf is 5-6 in ranked so far for -25 mmr.
A 100 games would be more than enough for a player to adapt to his higher ranked account...except he is really bad and not improving at all...I have a friend who improve a lot 2-3 months after buying a 4k accounts....well he got owned in every single game on his first month of course...
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How many games in your opinion(s) would someone have to play AND stay at the MMR on that bought account to be able to say they are that MMR? 50? 100? 300? Example: Someone buys a 4.1k mmr account and after 100 ranked games played they are still 4.1k