Third Circuit Upholds Tax Court In Large Dollar Horse Hobby Loss Opinion
He mentioned the Dreicer decision which is actually a sort of hilarious story of a trustifarian touring the world in search of the perfect steak. Dreicer lost in Tax Court and appealed to the DC Circuit (he was an expat). The Tax Court judge had indicated that it was not reasonable to expect a profit from the activity. The DC Circuit sent the case back to the Tax Court indicating that that was not the correct standards. What you have to have is the objective of making a profit, not the expectation. Back at the Tax Court again Dreicer still lost, but I give him credit for inspiring Reilly’s Eighteenth Law of Tax Planning – Honest objective trumps realistic expectation
Activision Blizzard CEO Bobby Kotick Hit With Huge Tax From 2001 Shelter
…there was this opportunity to make an investment. It was in a foreign currency trading hedge fund, and it came with great tax benefits. And he knew I was going to sell some stock that year so thought this would be a good investment and a good way to diversify because most of my net worth was tied up in my stock
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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.