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CCH (cch.taxgroup.com) reports:

A taxpayer's expenses were deductible and were not required to be capitalized as startup expenditures. The taxpayer deducted initial expenses of operating a horse boarding and training facility under Code Sec. 212, claiming that they were ordinary and necessary expenses incurred in the production of income. The IRS's argument that the expenses had to be capitalized under Code Sec. 195 because the taxpayer anticipated that her income-producing activities would become a trade or business was rejected. Code Sec. 195 was not intended to override the deductibility of ordinary and necessary expenses, whether incurred in an ongoing Code Sec. 212 activity or an ongoing Code Sec. 162 activity. The taxpayer's expenses were due to activities engaged in for profit and were fully deductible under Code Sec. 212.
J.A. Toth, 128 TC No. 1, Dec. 56,801
Other References:
Code Sec. 212
CCH Reference - 2007FED ¶12,523.3584
Code Sec. 195
CCH Reference - 2007FED ¶12,371.45
Tax Research Consultant
CCH Reference - TRC BUSEXP: 15,254