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Hobby or For Profit

Jet service activity wasn’t for profit, so taxpayer can’t claim losses in excess of income

Jet service activity wasn’t for profit, so taxpayer can’t claim losses in excess of income

Hoffmann, TC Memo 2016-69 The Tax Court has concluded that a taxpayer was not entitled to deduct losses from his jet service activity that exceeded the amount of income derived therefrom because the activity was not conducted with the intent of generating a profit. The Court found that, contrary to the taxpayer’s argument that he […]

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Seventh Circuit lambasts Tax Court on its hobby loss analysis in horse racing decision

Seventh Circuit lambasts Tax Court on its hobby loss analysis in horse racing decision

Roberts v. Comm., (CA 7, 4/10/2016) 117 AFTR 2d ¶ 2016-629 The Court of Appeals for the Seventh Circuit, reversing the Tax Court, has concluded that a taxpayer’s horse racing activities were entered into for profit. The Court characterized the Tax Court decision as untenable, in that it in effect concluded that a business’s start-up […]

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Court of Appeals – rent payments to shareholder by corporation engaged in hobby were taxable

Court of Appeals – rent payments to shareholder by corporation engaged in hobby were taxable

Estate of Stuller, (CA 7 1/26/2016) 117 AFTR 2d ¶ 2016-379 The Court of Appeals for the Seventh Circuit, affirming a district court opinion, has held that the activities conducted by an S corporation were not a trade or business and that the corporation was therefore subject to the limitations on deductible hobby losses. The […]

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Hobby Store Inherited By Art Teacher From Her Father Was A Business, Not A Hobby

Hobby Store Inherited By Art Teacher From Her Father Was A Business, Not A Hobby

Savello, TC Memo 2015-24   The Tax Court has held that a hobby store, that an art teacher inherited from her father and that she owned and managed while she continued to teach in a different state, was operated as a trade or business, not a hobby. Background. Code Sec. 162(a) allows as a deduction all […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney