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Federal Income Tax Update: Part 2

By Keith A. Wood

This is the second of two installments of this article. The first installment was posted on the Tax Section blog on Jan. 16, 2017.

I. Hobby Losses: Horse Breeder Had For-Profit Activity.

The 7th Circuit Court of Appeals reversed the Tax Court and held Mr. Roberts engaged in his horse training activity “for profit.”  Roberts v. Commissioner, 117 AFTR 2d 2016-629. The IRS disallowed certain horse breeding activity losses for 2005 through 2008. In reviewing all of the relevant facts, the Tax Court determined although Mr. Roberts did not engage in the activity for profit during the first two years, he was engaged in horse related activities for profit under Section 183 for the last two tax years.

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