America’s Hitler
My friend Tom Cahill has given me permission to republish his letters home from his voluntary exile in France. This is the fourth in the series. It will be daily...
Dressage Riding Physician Convinces IRS On Hobby Loss Audit But Loses To Massachusetts
here is little indication in the record that the appellant made any serious effort to develop expertise in the economics of training, leasing and selling horses as a business. The appellant argued that her consultations with various professionals demonstrated that she availed herself of the expertise of others in carrying on her activity. The Board found, however, that the lack of record keeping and lack of payment for these “consultations” was not indicative of a bona fide business relationship. In addition, her consultations with accountants were limited to the preparation of tax returns.
Similarly, the appellant failed to present evidence tending to distinguish her consultations with Wadsworth Farm’s owner and head trainer regarding the purchase and sale of her horses from those of an ordinary high-level amateur rider. Ms. O’Connell testified that she did not assist with the preparation of Dr. Thayer’s profit projections. While Ms. O’Connell and Dr. Thayer consulted often about matters of the horses’ training and wellbeing, Ms. O’Connell did not give any testimony that she advised the appellant with respect to the business of profitably training and selling horses.
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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.