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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