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FREED v. COMMISSIONER

Docket No. 11387-01.

88 T.C.M. 288 (2004)

T.C. Memo. 2004-215

Jane Freed v. Commissioner.

United States Tax Court.

September 23, 2004.

Attorney(s) appearing for the Case

William F. Rigsby, for petitioner.

Ronald T. Jordan, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1996 of $64,213 and an accuracy-related penalty under section 6662(a)1 of $409. After concessions,2 the sole issue for decision is whether petitioner operated her thoroughbred horse breeding and racing activities for profit in 1996. We hold that she did...

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