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Tax Court Treats IRS Auditor’s Greyhound Business as a Hobby

Paul Caron
,

The Tax Court yesterday denied an IRS auditor’s claimed $75k loss (over three years) in breeding greyhounds for racing because the actiivity was not engaged in for profit within the meaning of § 183.  Whitecavage v. Commissioner, T.C. Memo. 2008-203 (Aug. 27, 2008).  The court also sustained an accuracy-related penalty because "Petitioner has not shown (or even expressly claimed) that he had reasonable cause or acted in good faith with respect to his understatements of income tax. Any such defense appears especially problematic in the light of petitioner’s employment as an IRS auditor."

About the Author

Paul Caron Avatar
Paul Caron
Paul Caron was named Duane and Kelly Roberts Dean of Pepperdine University School of Law on June 1, 2017. Dean Caron joined the Pepperdine faculty in 2013 after serving as the Dorothy and Leonard Straus Distinguished Visiting Professor of Law in the spring semesters of 2010 through 2013. He served as Associate Dean for Research and Faculty Development at Pepperdine in 2015-2017. Before coming to Pepperdine, he was Associate Dean of Faculty and Charles Hartsock Professor of Law at the University of Cincinnati College of Law.
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3 responses to “Tax Court Treats IRS Auditor’s Greyhound Business as a Hobby”

  1. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  2. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  3. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  4. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  5. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  6. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  7. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  8. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…

  9. Roth & Company, P.C. Avatar
    Roth & Company, P.C.

    HOBBY LOSSES DOG IRS AUDITOR

    We were chatting about hobby losses recently. Yesterday we get a new case where a taxpayer got in trouble under…