Toth v. Comm'r
United States Tax Court
P began operating a horse boarding and training facility for profit in 1998. P has continued carrying on these activities through the date of trial. P claims the expenses paid for these activities are deductible pursuant to sec. 212, I.R.C., in 1998 and 2001, the years at issue.
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P began operating a horse boarding and training facility for profit in 1998. P has continued carrying on these activities through the date of trial. P claims the expenses paid for these activities are deductible pursuant to sec. 212, I.R.C., in 1998 and 2001, the years at issue. R denied the deductions, claiming that the expenses were nondeductible startup expenditures under sec. 195(a), I.R.C., which must be capitalized because they were incurred in anticipation of the sec. 212, I.R.C., activity's becoming a trade or business. Held: Sec. 195(a), I.R.C., does not require the expenses of P's…
1Opinion of the Court
JULIE A. TOTH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Toth v. Comm'r
Nos. 12452-04, 12862-04
United States Tax Court
128 T.C. 1; 2007 U.S. Tax Ct. LEXIS 1; 128 T.C. No. 1;
January 18, 2007, Filed
P began operating a horse boarding and training facility for
profit in 1998. P has continued carrying on these activities
through the date of trial. P claims the expenses paid for these
activities are deductible pursuant to sec. 212, I.R.C., in 1998
and 2001, the years at issue.
R denied the deductions, claiming that the expenses were
nondeductible startup expenditures under sec. 195(a),…
2Cases cited18 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Richmond Television Corp. v. United StatesSupreme Court of the United States · 1965
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