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Most Recent Posts

Tax Court Judge Emphasizes Magnitude Of Losses In Denying Horse Breeding Deductions

Tax Court Judge Emphasizes Magnitude Of Losses In Denying Horse Breeding Deductions

Mitchel and Eric clearly wanted to have a high-quality horse-breeding operation, and they spent generously to demonstrate that they were serious players in the Standardbred universe. But we find little evidence that they conducted this activity in a “businesslike manner,” i.e., in a manner intended to generate a profit. Many hobbyists desire to have a high-quality activity, but that does not necessarily mean that profit making is their goal. We regard this first factor as important in our analysis, and we find that it strongly favors respondent.

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A Revolutionary Tax Court Petition

A Revolutionary Tax Court Petition

Making this film in a charity means that historical accuracy will be paramount, free of the conflict of profit goals.  This creates a unique opportunity for those who care deeply about this story, and who have the wherewithal to make this film a reality.  Great pains have been taken to tell this story of our shared history in a compelling,

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Hobby Loss Deduction Developments In 2021

Hobby Loss Deduction Developments In 2021

Section 183 is one of the few areas where I think tax advisers are too cautious.  The law is clear that a realistic expectation of profit is not required to sustain a loss.  What is required is an honest objective. 

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IRS Automatic Notices Alienate Taxpayers

IRS Automatic Notices Alienate Taxpayers

Here is what I think happened.  Blynn’s timely response to CP 162 is still sitting in the IRS unopened mail pile.  They have their programs in place to issue a collection notice two weeks after not receiving a response to the CP 162.  They actually have a response, but the left hand doesn’t know that the right hand is not keeping up.

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Family Attorney Fears Tax Decision Smuggles Religion Into Family Law

Family Attorney Fears Tax Decision Smuggles Religion Into Family Law

The Court’s opinion in Grossman, which sets the dangerous precedent stating that a religious divorce can itself civilly dissolve a marriage, misapprehended multiple issues of New York State’s law, and violates the constitutional mandate that there be a separation between church and state. The effects of this decision are monumental.

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