Tax Coda

Tax Coda

Tax Court allows §183 business deductions for software venture

James D. Sullivan v. Commissioner. U.S. Tax Court. No. 15625-22. T.C. Memo. 2026-13.

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Tax Coda
Feb 09, 2026
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The Tax Court treated SelfChanger software work as a real profit-seeking venture, treated most Lincolnville land-development work as profit-motivated, and treated the “Leaf-Cutter” mulching Schedule C as a non-profit hobby loss.

Holding

The Court held that the Sullivans engaged in Traders Abacus’s software development activity for profit under §183 for 20…

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