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Most Recent Posts

Eleventh Circuit Deals IRS Defeat In Conservation Easement Struggle

Eleventh Circuit Deals IRS Defeat In Conservation Easement Struggle

The Hewitt court seems only to have held that the regulation was invalid because it failed the procedural regularity test. The Court never engaged with the issue of whether the interpretation (as opposed to the regulation) was a valid interpretation of the governing statute, § 170(h)(5)(A). There is thus the possibility that the IRS could or should still prevail if the interpretation is the best interpretation of the statute.

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Millennial Reviews The Old Man’s Tax Blog

Millennial Reviews The Old Man’s Tax Blog

Karen Slaughter is actually someone I know of- unlike the madcap tax dodgers my father usually casts for his posts. Doesn’t stop Peter from asking, just because I lived in the same state as his current obsession, if I’ve heard the name of some weird millionaire trying to deduct horse semen as hobby loss. 

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Tax Court Christmas Donkeys – A Present For Taxpayers With Losing Side Gigs

Tax Court Christmas Donkeys – A Present For Taxpayers With Losing Side Gigs

Taking Judge Urda’s narrative Huff and his wife Cathy Markey Huff did not raise their daughter Jennifer to be a trustifarian.  Mr. Huff capitalizing on her love of animals and her experience in greyhound rescue had helped her start Doggy Styles a pet grooming business.  He was concerned however that it was not enough so he and his wife started Ecotone

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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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