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Russell R. Kilkenny, for petitioner.
Shirley M. Francis, for respondent.
HAINES, Judge: Respondent determined deficiencies in
petitioner’s Federal income taxes for 1998 and 2001 (years at
issue) of $112,461 and $84,388, as well as additions to tax under
section 6651(a)(1) of $19,512 and $13,920, under section
6651(a)(2) to be computed, and under section 6654(a) of $3,806
and $2,349, respectively.
The issue for decision as framed by the parties is: whether
petitioner may deduct expenses in connection with her horse
boarding and training activities for the years at issue pursuant
to section 212 or instead is required by section 195(a) to
capitalize them as startup expenditures.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner lived in
Oregon when she filed her petition.
Petitioner was employed by the pharmaceutical firm Pfizer,
Inc. (Pfizer), from 1988 to May 9, 2000. In March 1997,
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended. All Rule references are
to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated. Amounts are rounded to the nearest dollar.
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Last modified: May 25, 2011