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during the years in issue. Only two of these foals were ever
sold. One foal, Jims Joy, was sold for less than $400, and the
other foal, Ramses Lady, was sold for $2,500. Petitioners also
bought horses, trained them, and hoped to resell them at a
profit. From 1983 through 1996, petitioners sold eight such
horses. Petitioners did not sell any horses during the years at
issue.
In addition to training and breeding horses, petitioners
showed their horses at various horse shows in order to advertise
their farm and increase sale opportunities. Petitioners did not,
however, advertise their horses in trade journals, magazines,
newspapers, or other publications during the years 1987 through
1995. Mr. Dodge, his daughter Andrea, or a trainer would show
the horses. Andrea Dodge would also show horses in the 4-H Club
(a youth organization). Petitioners knew that if a horse was
successful in the show ring, the value of the horse and its foals
would increase. Canadian Fury was very successful in the show
ring, becoming the reserve national champion in 1984.
In 1985, petitioners began raising cattle in addition to
horses. Petitioners generally purchased four steers each year.
Petitioners would buy the steers, feed them for 8 or 9 months,
and then sell them at a fair or over the market to a butcher. In
addition, petitioners occasionally boarded horses on their farm.
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