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Profit Motive

Tax Court holds longtime artist and art professor not snared by hobby loss rules

Tax Court holds longtime artist and art professor not snared by hobby loss rules

Crile, TC Memo 2014-202 The Tax Court has held that a tenured art professor and career artist had a profit motive with respect to her art under Code Sec. 183 and was engaged in the trade or business of being an artist within the meaning of Code Sec. 162(a) during the years at issue. Click […]

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Taxpayer’s sports memorabilia activity was not engaged in for profit

Taxpayer’s sports memorabilia activity was not engaged in for profit

Akey, TC Memo 2014-211 The Tax Court has held that a taxpayer who had a full-time job as an engineer, had a software, etc. consulting business on the side, and sold sports memorabilia did not engage in the sports memorabilia activity for profit. Click here for the Opinion of the Court. Background. Code Sec. 162(a) […]

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No profit motive in partnerships organized to make charitable contributions

No profit motive in partnerships organized to make charitable contributions

McElroy, TC Memo 2014-163 The Tax Court has concluded that a taxpayer lacked the requisite profit motive under Code Sec. 165(a) and Code Sec. 165(c)(2) to deduct the losses he claimed with regard to his investment in three partnerships that were organized with the goal of providing investors in the partnerships with charitable contribution deductions. […]

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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