A Sordid Tale of Donkeys and Horses: Tax Court Style – Part One

The following tale is the first in a two part series relating to a couple of recent decisions from the United States Tax Court. Both decisions center around the often-litigated topic of a taxpayer’s profit-motive and whether those taxpayers should have been the allowed the losses stemming from their breeding businesses. On December 21, 2021, [...]

Winning A Tax Battle, But Losing the Tax War

A recent U.S. Tax Court decision in Barker v. Comm’r of Internal Revenue, T.C. Memo. 2018-67 exemplified the notion that a taxpayer could win a significant tax battle, but still lose the tax war. Cecile Barker was a successful aerospace engineer who also operated a music production/promotion company called SoBe. Cecile’s son was among the [...]

Substantiating Business Expenses in Audits – Step Two: Proving a “Trade or Business” Incurred the Business Expenses

Substantiating business expenses is a common problem for many businesses going through an audit with either the Internal Revenue Service (IRS) or the Minnesota Department of Revenue (MDR). In a previous blog article, we addressed the first step of a four step process in an IRS or MDR substantiation audit: proving the payment of expenses. [...]

Professional Gamblers

In the State of Minnesota, many gamblers are interested in taking the extra steps to be treated as professional gamblers. In contrast to the treatment the gambler receives from the IRS, a non- professional gambler in Minnesota is subject to the Alternative Minimum Tax and, as a result, is not allowed his or her gambling [...]

Profit Motive: Activities Not Engaged In For Profit and "Hobby Losses"

Many taxpayers are fortunate enough to turn a hobby or an activity they are passionate about into a business. The IRS, however, too often determines that the taxpayer’s business is not a “real business” when the business loses too much money. While sometimes the IRS determination is right, many times the IRS will incorrectly re-characterize [...]

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