7confidencegames
Brendan Beehan 360x1000
1lauber
Maria Popova 360x1000
2theleastofus
1confidencegames
LillianFaderman
1lookingforthegoodwar
1jesusandjohnwayne
10abion
Storyparadox1
1paradide
1trap
AlexRosenberg
2lookingforthegoodwar
2albion
Margaret Fuller3 360x1000
lifeinmiddlemarch2
3paradise
1empireofpain
Margaret Fuller 360x1000
1falsewitness
1madoff
Margaret Fuller5 360x1000
9albion
Thomas Piketty1 360x1000
George F Wil...360x1000
399
3confidencegames
199
Margaret Fuller4 360x1000
2trap
Margaret Fuller 2 360x1000
George M Cohan and Lerarned Hand 360x1000
5albion
Thomas Piketty3 360x1000
lifeinmiddlemarch1
Anthony McCann1 360x1000
Susie King Taylor2 360x1000
Margaret Fuller1 360x1000
storyparadox3
1theleasofus
Mary Ann Evans 360x1000
7albion
3albion
499
James Gould Cozzens 360x1000
Susie King Taylor 360x1000
Mark V Holmes 360x1000
1gucci
11632
3theleastofus
Lafayette and Jefferson 360x1000
12albion
Ruth Bader Ginsburg 360x1000
Thomas Piketty2 360x1000
3defense
Betty Friedan 360x1000
13albion
Stormy Daniels 360x1000
Learned Hand 360x1000
14albion
5confidencegames
11albion
2gucci
Edmund Burke 360x1000
Anthony McCann2 360x1000
2lafayette
6confidencegames
Samuel Johnson 360x1000
4confidencegames
Adam Gopnik 360x1000
Office of Chief Counsel 360x1000
2jesusandjohnwayne
8albion'
Richard Posner 360x1000
4albion
Margaret Fuller2 360x1000
1defense
Spottswood William Robinson 360x1000
storyparadox2
6albion
1albion
2confidencegames
2falsewitness
1transcendentalist
2transadentilist
Maurice B Foley 360x1000
Gilgamesh 360x1000
Tad Friend 360x1000
2paradise
299
2defense
1lafayette

Tax Advisers Are Too Afraid Of The Hobby Loss Rules

Section 183 was enacted as part of the Tax Reform Act of 1969.  Regulations were issued in 1972.  They are mostly unchanged.  One of the earlier people to run up against Section 183 was Maurice Dreicer.  In 1979, the Tax Court upheld deficiencies totaling $30,000 for 1972 and 1973. (You could call that $180,000 in today’s dollars).

Mr. Dreicer’s “business” was traveling around the world and going to fine restaurants which would endeavor to serve him the”perfect steak”.  He was planning a book titled My 27 Year Search for the Perfect Steak — Still Looking.  He was already a published author with The Diner’s Companion.

Although it ended up not doing him any good Dreicer’s winning appeal to the DC Circuit set an important precedent.

We perceive no basis for disturbing the Tax Court’s finding on the nature of the undertakings generating the losses for which deductions are sought. We do not accept, however, the legal test that the court employed in ruling on deductibility. We hold that a taxpayer engages in an activity for profit, within the meaning of Section 183 and the implementing regulations, when profit is actually and honestly his objective though the prospect of achieving it may seem dim . Because the Tax Court applied a different standard, we reverse and remand for redetermination of Dreicer’s deduction claims. (Emphasis added)

read more

Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.