Articles from Author John Alan Cohan, Attorney at Law

Enjoy all the Following Articles Written by John Alan Cohan, Attorney at Law

John Alan Cohan
May 16, 2012
John Alan Cohan, Attorney at Law

The Tax Court held that a married couple who engaged in a cattle and horse breeding activity were not engaged in a business, despite the full-time nature of the venture. The case was Garbini v. Commissioner IRS [T.C. Summary Opinion 2004-7]. Mr. Garbini, of Myrtle Creek,...

business, horses, IRS, Taxes
John Alan Cohan
March 7, 2012
John Alan Cohan, Attorney at Law

Sometimes a farm, livestock or horse activity may be closely connected to one’s principal occupation, with certain tax advantages. If two activities are treated as one, deductions and income from each activity can be aggregated in deciding whether the taxpayer has the...

John Alan Cohan
January 16, 2012
John Alan Cohan, Attorney at Law

A recent case that seemed to rule correctly against a taxpayer was the Tax Court decision holding against Sandra J. Brannon of Southwest Texas with regards to her quarter horse breeding activity. [Brannon v. Commissioner IRS, TC Memo 2000-76.] The case also denied her...

IRS and horse businesses
John Alan Cohan
December 15, 2011
John Alan Cohan, Attorney at Law

Otis and Alma Jordan of Amissville, Virginia persuaded the Tax Court that their horse racing and breeding activity was engaged in for profit. The couple lived on a 20-acre farm on which they constructed a new barn and made other significant improvements. They owned several...

horse racing, horses, IRS, tax law
John Alan Cohan
November 8, 2011
John Alan Cohan, Attorney at Law

Stallion Syndicates have been a popular vehicle for people engaged in breeding activities for over 40 years. This is a mode of co-ownership that applies to all types of horses in all breeds. During the 1980s, many people syndicated high quality stallions as investment and...

John Alan Cohan, Attorney at Law
October 6, 2011
John Alan Cohan, Attorney at Law

Often enough the IRS will “trick” taxpayers by questioning whether they satisfy the Material Participation Test. This happens if the IRS concedes that your farm, livestock or horse activity is conducted for profit under the hobby loss rule. That in itself is usually a big...

John Alan Cohan, Attorney at Law
September 8, 2011
John Alan Cohan, Attorney at Law

A new Tax Court case, Blackwell v. Commissioner IRS [T.C. Memo 2011-188] involved taxpayers who were reasonably well qualified to engage in a horse breeding activity and who convinced the court that they had the opportunity or the potential to earn a profit in their venture....

equine industry, IRS
John Alan Cohan, Attorney at Law
August 4, 2011
John Alan Cohan, Attorney at Law

Under the IRS hobby loss rule if you have losses in connection with any farming activity, horses, livestock or crops, the IRS may suspect that the activity is engaged in as a hobby rather than a business, particularly if there is a history of losses. One of the elements in...

tax issues and horses
John Alan Cohan, Attorney at Law
July 14, 2011
John Alan Cohan, Attorney at Law

Tax Court cases can be appealed to the Court of Appeals for the Circuit in which jurisdiction lies. It is extremely rare for a taxpayer to take such an appeal because of the cost involved and the unlikelihood of prevailing on appeal. However, a recent such appeal occurred...

horse business, Horse industry, IRS
John Alan Cohan, Attorney at Law
June 6, 2011
John Alan Cohan, Attorney at Law

Taxpayers Win Tax Court Ruling in Horse Case
By John Alan Cohan, Attorney at Law

In a new Tax Court case, Richard and Delores Frimml of Luzerne, Iowa won on the question of whether their horse activity was to be treated as a business [T.C. Summary...

attorney, court, horse case, law, laywer, legal, tax, taxpayers