I am blogging James P. Donoghue and Elaine S. Donoghue, 2019 T. C. Memo. 71, filed 6/11/19, not for any novel legal propositions, nor for any off-beat factual circumstances, therein set forth, but rather for the delectation of my colleague Peter Reilly, CPA.

Mr. Reilly has made a substantial collation of hobby horse and similar Section 183 “goofy regulation” cases. This one poses no new concepts, and the facts are straightforward enough.

Mrs D loves horseracing ever since her beloved grandfather introduced her to same. She went in for virtual horsefarming (her “farm” was various use-by-the-day premises, brought together on the internet) and breeding, but rarely raced her horses, and lost $974K over 35 years. She claimed to be a “continuous start-up.”

Judge Ashford wasn’t amused. And wasn’t buying.

Take it away, Mr Reilly.