The U.S. Tax Court recently ruled in WP Realty, LP, Olympia Realty, Inc., Tax Matters Partner v. Commissioner of Internal Revenue that the Internal Revenue Service improperly rejected a taxpayer’s business deductions related to a golf course property.
Bloomberg Tax reported on the decision in a Sept. 16 article that detailed the court’s decision.
The leadership of alliantNational, as parties of the associated law firm Zerbe Miller Fingeret Frank & Jadav LLP, represented the taxpayer in the case, which will have broad implications for high-net worth taxpayers whose claimed business losses have come under Internal Revenue Service scrutiny.
“The court held that WP Realty was operating a golf course with the objective to make a profit under tax code Section 183. This meant it could deduct $14,335,598 for activities the IRS had found weren’t deductible for tax years 2011 to 2014,” wrote Aysha Bagchi of Bloomberg Tax.
The Tax Court found that the taxpayer had a “predominant, primary, or principal objective” to realize an economic profit outside of the deductions claimed.
“We are so pleased to see this decision result in the right outcome for our client. Many entities are trying to make a profit and our experts which include, Steven Miller, who actually established Global High Wealth Audits at the IRS, are here to help companies navigate the increased scrutiny we are seeing nationwide,” said Shane Frank, Chief Operating Officer at alliantNational.
The full decision can be read here.