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SKOLNICK v. C.I.R.

Nos. 22-1501, 22-1502, and 22-1503.

62 F.4th 95 (2023)

Mitchel SKOLNICK; Leslie Skolnick, Appellants in No. 22-1501 v. COMMISSIONER OF INTERNAL REVENUE. Mitchel Skolnick; Brianna Skolnick, Appellants in No. 22-1502 v. Commissioner of Internal Revenue. Eric Freeman, Appellant in No. 22-1503 v. Commissioner of Internal Revenue.

United States Court of Appeals, Third Circuit.

(Filed: March 8, 2023).

Attorney(s) appearing for the Case

Bryan E. Bloom , Kevin H. DeMaio , Faegre Drinker Biddle & Reath, 600 Campus Drive, Florham Park, NJ 07932, B. Paul Husband , Law Offices of B. Paul Husband, 101 South First Street, Suite 202, Burbank, CA 91502, Richard W. Craigo , 10724 Wilshire Boulevard, Suite 406, Los Angeles, CA 90024, Counsel for Appellants.

David A. Hubbert , Janet A. Bradley , Joan I. Oppenheimer , United States Department of Justice, Tax Division, Room 4738, 950 Pennsylvania Avenue, N.W., P.O. Box 502, Washington, DC 20044, Counsel for Appellee.

Before: HARDIMAN, KRAUSE, and MATEY, Circuit Judges.

OPINION OF THE COURT

Mitchel Skolnick, Leslie Skolnick, Brianna Skolnick, and Eric Freeman (collectively, Taxpayers), appeal an order of the United States Tax Court. They argue the Court clearly erred when it held their horse activity—undertaken through Bluestone Farms, LLC (the Company)—was "not...

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