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 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 sec. 212, I.R.C., activity to be capitalized as startup expenditures. The expenses paid or incurred in the sec. 212, I.R.C., activity are deductible.Page: 1 2 3 4 5 6 7 8 9 10 Next
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