Phemister v. Comr., T.C. Memo. 2009-201

(taxpayer did not engage in horse activity with intent to make a profit - over $500,000 of losses not fully deductible; addition to tax for failure to timely file return applied as did 20 percent penalty for substantial underpayment of tax; taxpayer's spouse entitled to spousal relief from joint and several liability with respect to understatements of tax resulting from disallowance of taxpayer's ER physician business expense deductions, but is not entitled to relief from tax deficiencies arising from horse activity).