This course explores the nine factors the IRS uses to determine whether an activity is engaged in for profit or as a hobby under IRC §183. Drawing on 17 years of experience inside the IRS — including 10 years as a Revenue Agent and 7 as an Appeals Officer — Israel Ostrov offers a clear, insider’s perspective on how to evaluate, document, and defend profit motive. Participants will gain practical tools to apply these principles in audit and advisory settings.

The major topics covered in this class include:
Identify the nine factors under IRC §183 used to determine profit motive.
Evaluate taxpayer activities to distinguish between hobby and business.
Understand how the IRS weighs documentation, consistency, and taxpayer intent.
Apply practical examples and case studies to defend a taxpayer’s position.
Advise clients on best practices to strengthen a profit motive case before examination.
Who should attend:
EAs with clients who have small businesses
2 CE hours
Prerequisites: None
Program Level: Basic
Advanced Preparation: None
Delivery Method: Group Internet Based

Israel Ostrov
Enrolled Agent
Israel Ostrov, EA, is a former IRS Appeals Officer and Revenue Agent with over 17 years of experience in federal tax examination and resolution. During his tenure with the IRS, he handled complex individual and business cases involving audits, appeals, and tax controversy. Israel now operates Tax Flow Resolution, where he helps taxpayers and practitioners navigate IRS disputes with clarity and confidence. His teaching style combines technical depth with practical insight, helping professionals understand not just what the IRS looks for — but why.