Curtis v. Commissioner

OPINION.

Seawell:

Petitioner’s deficiency in income tax as determined by the Commissioner for the year 1928, amounting to $863.60, results from the disallowance by the Commissioner of a deduction of $6,908.78 from gross income claimed by petitioner as an expense of the operation of a racing stable conducted as a business by her during that year.

The petitioner is an individual, residing in Washington, D.C. In 1928 she was engaged in running two shops, one in Washington and one in New York, and she had profitable investments in securities. She was interested in horses and discussed with others…