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  • Holly Roundtree CPA

2019 – 08/21

Taxpayers engaged in business, with the intent to make a profit, can generally deduct the related expenses on their tax returns. One taxpayer formed partnership agreements with cocoa farmers in Ghana. In exchange for 50% ownership and 50% of future profits, he made capital contributions to the partnerships ranging from $2,500 to $25,000. He also agreed to make future loans. On his tax returns, he filed Schedule C for the business of “farming activity.” He deducted farm expenses and claimed no revenue. The IRS denied the deductions, stating that his involvement in the farms didn’t rise to the level of a business. The U.S. Tax Court agreed and disallowed the deductions. (TC Memo 2019-98)

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