In Uncategorized on 02/13/2017 at 19:15

The rap on tax law is that it’s hypertechnical, dry-as-dust, and devoid of humanity. We tax lawyers are deemed to wander in this murky No-One’s-Land, gabbling unintelligibly to others similarly situated.

Well, today Mohammad M. Zarrinnegar and Mary M. Dini, 2017 T. C. Memo. 34, filed 2/13/17, bring some warmth on a cold afternoon, and even ex-Ch J Michael B (“Iron Mike”) Thornton has a grin to spare for Mo’s story.

Mo is a dentist, but he spends most of his logged hours running four (count ‘em, four) rental properties and real estate brokering. Mary is also a dentist, drilling and filling in the family tooth shop while Mo is brokering and managing.

Mo’s logs stand up for the 750 hours, even when most of his deductions crash on non-substantiation, inconsistent testimony, and illegible receipts.

So Mo’s a pro, and he gets his losses.

But the brokerage gig is what the jazz musicians of an earlier age called a “hame,” an unprofitable performance.

Mo is not a whit dismayed. And ex-Ch J Iron Mike is down wit’ that, as we say on this Minor Outlying US island off the Coast of North America.

“Petitioner husband testified that throughout the years at issue he had high hopes for the brokerage side of the business, despite the financial malaise burdening the housing market.  Undaunted despite earning only $8,500 in brokerage fees during the years at issue, petitioner-husband testified that he poured hundreds of hours each year into broker’s tours, listing searches, open houses, property viewings, client meetings, and other related activities, likening his efforts to the early labors of Bill Gates and Mark Zuckerberg, who toiled in obscurity and relative poverty before reaping fabulous profits.” 2017 T. C. Memo. 34, at p. 16, footnote 11.

Toiling in obscurity, that’s us, Mo.

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