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Deductibility of Hobby Losses: Horse breeding
Wilson v. Commissioner of Internal Revenue
United States Tax Court

The following is a list of criteria the court ruling emphasized in upholding the taxpayer's deduction for horse breeding losses:

 The manner in which the taxpayer carries on the activity
The petitioners carried on the activity in a businesslike manner; they advertised, attended seminars, kept consistent records with intent to improve profitability. In additional, they abandoned an unprofitable method- in a manner consistent with intent to improve profitability (i.e., determining that the Skipper W bloodline would be more profitable).
 The expertise of the taxpayer or his advisers
Ms. Wilson had significant experience training horses and petitioners consulted with experts relating to the caring, feeding, and training of horses. In addition, petitioners regularly consulted with their accountant with respect to the activity's books and records.......

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Approximate Word Count: 497
Approximate Pages: 2 (250 words per double-spaced page)

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