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399
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TIGTA Pushes IRS To Crack Down On Hobby Loss Deductions

TIGTA Pushes IRS To Crack Down On Hobby Loss Deductions

Apparently a dinky Schedule C is more suspicious than a loss flowing through from an S corporation or partnership.  A lot of practitioners will advise you to put your enterprise in an entity for that purpose.  I am hesitant to give that advice because then there is another return that might get audited.  I have not been able to figure out how to balance those two factors.

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Tax Court Rules International Waters Not Foreign Country But Misses That Mariners Are Not Marines

Tax Court Rules International Waters Not Foreign Country But Misses That Mariners Are Not Marines

The Court is not aware of a valuation issue between the parties. Petitioner had employed his preparer for 20 years and relied upon his expertise to report that petitioner’s income was exempt under section 911(a). The preparer was informed about petitioner’s residence and the facts surrounding his income earned during international voyages on cargo ships. The reporting position had been approved for earlier years, and it was reasonable for petitioners to rely on the preparer under these circumstances. Accordingly, we hold that petitioners are not liable for accuracy-related penalties with respect to any underpayments that may result from our holding on the section 911(a) issue.

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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.