It less an issue of quantity but more of type. By that I mean, you could easily merge 100 mods, and not have any problems. But if you merge the wrong two mods, you will bash your head against a wall.
Fairly new to the whole merging thing myself. But my general rule of thumb is, merge armor/weapon/graphic mods that other things are not dependent on. I also tend to throw in *very* limited mods that tweak quests. Like adding map markers to stones of B(something), or markers for the dragon face masks.
edit: Then if the merge throws up any errors, start isolating the problem mod, and not include it. Its not worth the potential grief that can come to haunt you. Oh, and try a bashed patch with your merge active. If the bash throws an error, its not a good sign.