Auto Dealerships Are Separate Activity From Horse Activity Under Hobby Loss Rules.

The petitioner was a third-generation auto dealer with successful dealerships, and his family has been involved in horse-related activities since the 1960s.  The petitioner started his own horse activity in 1993.  For various reasons, the horse activity lost money for the years in issue, but the petitioner argued that the auto dealerships and the horse activity constituted a single activity for purposes of I.R.C. Sec. 183.  The court held, however, that the activities were separate.  Based on the evidence, the court noted that the activities were not conducted in the same locations and there was no relationship between the customers of the horse activity and the customers of the auto dealerships.  In addition, there was minimal cross-advertising between the activities and there was no leasing of assets between the two activities.  The court also noted that the activities were not similar in nature.  Price v. Comr., T.C. Memo. 2014-253.

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