IIMPORTANT 3 to 5 Year Old Program Reining Information
In the 3-5 year old program, (3-5 Ranch Reining) it is recommend that Pattern 7 be used.
Horses entered in the 3-5 program are not required to do flying lead changes. In 3-5 Ranch Reining, horses may perform a simple or flying lead change there is no penalty or advantage for either. However, failure to change leads will be penalized as per the rules for reining on page 44 of the 2013 Rule Book but with a maximum penalty of 4 points per circle.
Should you have any questions, please contact this office and we will get your question(s) to the appropriate individual for clarification.
This is effective immediately.
2013 World Round Up & Review Info And Entry Forms Are Ready.
We've finished our class list and entry forms for this year's World Round Up & Review. There are lots of opportunities for riders of all levels and something for everyone's interest. We've made it easy again with our electronic PDF entry form. We'll be more than happy if all you do is come and show with us, but if you want to help out even more we're looking for sponsors too. We will once again produce our full-color show booklet with all the info about the show and full-color ads for our sponsors. Remember this is "Cornhusker Football Country" and once again our show falls on the weekend of a big game. Because of this you'll want to reserve your hotel rooms early with the hotels that are partnering with us this year. CLICK HERE and you will see the entry form, sponsor info and lodging details on our World Round Up & Review page. Look it over, fill 'em out and send 'em in. We look forward to seeing your at this year's WRR!
9th Edition Rule Book Is Here
There are several new classes, and much of our national membership feeback and input has been included in the latest edition of the FQHR Rule Book.
THE IRS’S MISGUIDED APPROACH TO “RECOUPMENT”
By John Alan Cohan, Attorney at Law
For any business, long-term profit potential may hinge, in some measure, on efforts to reduce costs, getting better prices for goods and services, consolidating operations, layoffs, or efforts to promote efficiency.
For many people in the horse or livestock business, the operations have a history of losses, but the expectation is that future operations will be profitable. The IRS will want to see evidence that the taxpayer has taken steps to correct or abandon unprofitable strategies, and to demonstrates steps taken to improve operations.
Often, the IRS will argue that a profit motive ultimately depends on whether the taxpayer expects future earnings and appreciation to be sufficient to recoup accumulated losses of prior years. The IRS will want to see a meaningful plan for recouping losses sustained in prior years.
This seems inherently unfair. Other businesses are not asked to demonstrate a plan to recoup past losses. In some industries past losses have been so great that the companies might never really end up recouping them.
According to Terrence D. Miller, CPA, of Miller and Miller Accountancy Corporation in Fresno, California, “In my experience with audits, quite often an auditor will be obsessed with the cumulative losses and they fixate on it. And the losses might not ever be recoupable. Luckily there is a Tax Court case on the subject and usually when you show auditors this case they move on.”
He is referring to Helmick v. Commissioner IRS, T.C. Memo 2009-220, which involved a horse breeding and boarding operation with losses for a period of 17 years. The Tax Court held in favor of the taxpayers, and rejected the IRS “recoupment” argument.
The court said that the IRS “seems to assume that the requisite profit motive as of any given year must involve an expectation that even all past losses will be recouped, so that the activity will have generated a net profit over its entire course. This position distorts the notion of profit motive for purposes of section 183.”
The court cited a hypothetical example: “If a natural disaster caused the death of 90 percent of a rancher’s herd and resulted in a catastrophic loss that could never be recouped, but the rancher thereafter expected to generate an overall prospective profit by breeding and selling the remaining 10 percent of his herd on a foregoing basis, then he could not be said to lack a profit objective after the disaster merely because he would never recoup the prior loss.”
The court pointed out – and this is very important – that the “recoupment” concept is forward looking. That is, the profit objective is shown where the taxpayer expects that the activity will generate an overall profit between the year being audited and the time at which future profits are expected.
To some extent, taxpayers often can explain a poor history of profits due to circumstances beyond their control, including personal issues, casualties, stillborn foals, and the negative effect of the recession on horse sales. The implication is that the activity, in a given year, would have been profitable if these events had not occurred.
Whether an activity producing losses is a business or a hobby is a question that has generated substantial litigation in U.S. Tax Court. If faced with an audit of horse or livestock activities, it can be frustrating when confronted with an IRS auditor who wheels out the “recoupment” argument. Thankfully, there are Tax Court cases, such as that mentioned above, that provide a rational approach in determining whether the taxpayer has a bona fide profit motivation.
[John Alan Cohan is a lawyer who has served the horse, livestock and farming industries since l98l. He can be reached at: (3l0) 278-0203, by e-mail at moc.loa@nahocnalanhoj">moc.loa@nahocnalanhoj, or you can see more at his website: www.johnalancohan.com.]
2012 FQHR World Round Up & Review Wrap Up
The 2012 FQHR World Round-Up & Review was held in Lincoln, Nebraska just a month ago. It’s so nice to report all the positives. There were 627 entries and that’s an increase of over 25%. That is a direct reflection to the increase in both FQHR memberships and registrations and in part to the FQHR Nebraska show being part of this year’s Nebraska State Fair. The State Fair was held in Grand Island just two weeks before the WR&R in Lincoln. Those of us who attended the WR&R but not Nebraska State Fair saw first-hand the enthusiasm that carried from the first show to the second.
The FQHR office has made believers out of numerous members who have been at times shocked at the turn-around of both registration and membership applications. Requests filled the office following the State Fair and everyone who wanted to come to the Round-Up & Review were able to come with completed paperwork in hand.
One of the nicest parts of the WR&R is seeing so many people that exhibitors do not see the rest of the year. Cattle classes were full and an excellent example of exhibitors working together. I was asked by a cutter if there was help out there if she decided to go next year. The answer was “Yes, lots and nothing to worry about”. There are many attributes to FQHR but the most obvious is the friendliness of the exhibitors toward visitors and other exhibitors. Refreshing, absolutely refreshing.
The Lancaster Event Center is an excellent facility very conducive to caring for and showing horses. Safe stalls, handy wash racks and good footing all help horses and horsemen be the best they can be. The Handy Ranch Horse class was held in a separate arena and exhibitors were able to exhibit in that class while other classes were going on in the main arena.
Class sponsors supported the show and aided the committee in securing saddles, buckles and other nice awards that were presented to the winning exhibitors immediately following the end of the show. As always the committee welcomes both advertisers for the program and class sponsors for the awards for the show next year.
The contract has been signed for next year and the committee has already met to plan new classes, awards and strategies to make the World Round-Up & Review 2013 bigger and better than ever. If anyone has suggestions please do not hesitate to offer to contact any of the committee members or the main office.
The FQHR World Round Up & Review Committee
Lazy Rafter Quarter Horses
Tom & Shirley May are owners of Lazy Rafter Quarter Horses, located south of Hutchinson, KS on the family farm established in 1904. Read More
Just a note to let you know what a blessing it has been for Kaye to be able to participate in the foundation shows locally. She works so hard practicing and tells everyone how proud she is to be able to show her horse. Read More