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, [...]
The United States Department of Treasury (the Treasury) issued “The American Families Plan Tax Compliance Agenda,” detailing how the current administration intends to tackle the ever-looming noncompliance issue. This report was a follow up to the April of 2021 American Families Plan that included proposals that the administration announced to increase tax compliance. The Treasury [...]
People often joke that the only certainties in life are death and taxes. Well, it turns out that, when it comes to the report of Foreign Bank and Financial Account (FBAR) penalties, death may have finally met its match. The Southern District of Florida issued a decision in United States v. Green, 2020 BL 165965 [...]
The fight over who meets the definition of a “real estate professional” is not a new one. Fortunately, the taxpayer’s burden for satisfying that definition has only been eased by the expansion of digital tools available for tracking time. That being said, the United States Tax Court’s (Court’s) memorandum opinion in Hairston v. Comm’r of [...]
For many taxpayers with multiple active business interests, the material participation test can be a significant tax trap. If the elements of that test are not met, the impact could be that the taxpayer is limited in how the income/loss from that business is recognized on their personal tax return. A recent decision in the [...]