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Appreciation And A Strong Manager Win Hobby Loss Case

by admin | Jan 22, 2023 | Tax

The first Tax Court hobby loss opinion of the year is a taxpayer win. Paul and Patricia Wondries were facing deficiencies totaling $421,503 for the years 2015-2017. The issue was whether their 1,100 acre ranch was being run with the objective of making a profit. ...

Some Of The Tax Developments I Covered In 2022

by admin | Jan 7, 2023 | Tax

I have been a tax writer of sorts for thirteen years. What I write about is stuff that I find interesting. And I have to tell you that 2022 does not rate that high for interesting. Still there were a few things worth remembering. On reflecting on what I find...

IRS Versus Dubious Conservation Easements In 2022 – Mixed Results

by admin | Jan 4, 2023 | Tax

Kenneth M. Brooks v Com may be the final decision this year in the IRS battle with dubious conservation easement deductions. The IRS disallowed the deduction on three separate grounds independent of valuation. There was not a proper acknowledgement by the donee,...

EO Tax Journal Editor Proposes Elimination Of All Charitable Deductions

by admin | Dec 30, 2022 | Tax

There was a real shocker in the December 6th (2022-218) issue of the EO Tax Journal. In the Editor’s Notebook section Paul Streckfus was commenting on an article by Roger Coinavaux calling for reform of donor advised funds. Streckfus was his usual gloomy self...

Should You Invest In A Syndicated Conservation Easement ?

by admin | Dec 23, 2022 | Tax

As somebody who believes that the syndicated conservation easements (SCE) constitute an industry based on nonsense, I want to be able to tell you that if you are offered the chance to participate in one, you absolutely should not. I can’t really do that though. ...

IRS Successfully Attacks Tax Shelter With Hobby Loss Rule

by admin | Dec 15, 2022 | Tax

Tenth Circuit upholding the Tax Court’s ruling in the case of Preston Olsen may signal the revival of a once successful IRS technique for attacking tax shelters. Code Section 183 – Activities not engaged in for profit – is commonly rereferred to as...