- 4 - petitioner had established a limited liability company called Ghost Oak Farm, L.L.C., to operate the Newberg property. She currently earns approximately $3,000 per month from Ghost Oak Farm, L.L.C. Petitioner filed her Federal income tax returns for the years at issue on April 5, 2004. Respondent sent petitioner notices of deficiency for the years at issue on April 19 and 26, 2004, respectively. The notices of deficiency for the years at issue were based upon third party payor information and not upon information reported on petitioner’s filed returns. The parties have stipulated that the income reported on petitioner’s Federal income tax returns for 1998 and 2001 is correct. Petitioner’s claimed itemized deductions are not in dispute. Petitioner reported the income and expenses from her horse boarding and training activities on Schedule C, Profit or Loss From Business, but concedes that the expenses attributable to the activities are not deductible pursuant to section 162. Rather, petitioner contends that the horse boarding and training expenses are deductible pursuant to section 212. Respondent concedes petitioner engaged in horse boarding and training activities for profit5 beginning in 1998 and does not dispute the 5 Respondent does not argue the application of sec. 183.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011