TOTH v. COMMISSIONER

Docket Nos. 12452-04, 12862-04.

128 T.C. 1 (2007)

128 T.C. No. 1

JULIE A. TOTH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 18, 2007.


Attorney(s) appearing for the Case

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...

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