Partnership Needs More Than One Partner
If the deal had otherwise worked it would have been really devastating to lose it on that basis, since an election by the disregarded entities to be treated as corporations would have saved it. Actually it was just another nail in the coffin, but one to watch out for in transactions of more substance.
Bill Romanowski's Tax Court Loss Not A Typical Horse Case
The bottom line is that both the Romanowski and Pederson are really bad tax shelter cases rather than horse breeding cases. It strikes me as odd that somebody who was going to promote a tax shelter would uses horses, since the business already has red flags associated with it. I keep a rough tally in my head of what activities are most likely to win hobby loss cases. Car racing and Amway do not do well at all. Horse breeders, on the other hand, frequently win, although the IRS keeps going after them. Whatever anybody else thinks, I’m not going to count these cases against actual horse breeders.
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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.