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We have found that petitioner operated her horse boarding
and training activities for profit in 1998 and has continued to
engage in these same activities through the date of trial.
Respondent concedes petitioner engaged in these activities for
profit during the years at issue. Additionally, respondent does
not argue the application of section 183 and does not dispute the
amounts of the expenses or that they were ordinary or necessary.
Therefore, the Court holds that petitioner’s expenses
attributable to her horse boarding and training activities during
the years at issue are deductible pursuant to section 212.
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011