Farm Hobby Losses with Cattle Operations and Horse Activities (IRC Section 183): IRS Audit Techniques Guide

The Market Segment Specialization Program (MSSP) Audit Techniques Guide (ATG) on IRC section 183 Farm Hobby Losses has been developed to provide guidance to Revenue Agents and Tax Auditors in pursuing the application of IRC section 183 with respect to horse activities and cattle operations. Historically, IRC section 183 has been a difficult issue to pursue. The development of the issue is a fact-gathering initiative. The application of IRC section 183 is based upon the examiner's understanding of the taxpayer's industry as well as the taxpayer's mode of operation within that industry. IRC section 183 and the accompanying Treasury Regulations do not provide absolute definition, but serve to provide guidance in formulating the facts into a conclusion. Hazards of litigation have also been a deterrent toward the pursuit of IRC section 183. As a result, examiners have been reluctant to allocate exam time.