Julie A. Toth v. Commissioner

128 T.C. No. 1

UNITED STATES TAX COURT JULIE A. TOTH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 12452-04, 12862-04. Filed January 18, 2007. 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…