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full-time employment with Borg Pontiac, an automobile dealer, and
then at Village Pontiac, another automobile dealer. In 1993, Mr.
Reimer testified that he made a conscious decision to end his
involvement with NSA. Mr. Reimer terminated the NSA activity
either in 1993 or early in 1994, at the latest, by writing a
letter of termination and returning all remaining inventory to
NSA.
Mr. Reimer’s NSA activity was reported on Schedules C for
the tax years 1991 through 1994, as a secondary activity separate
from petitioners’ horse breeding activity.
C. Horse Breeding Activity
Petitioners’ horse breeding operation first began around
1976. This activity was originally named J-Mar Arabians.
Petitioners changed the name to Summer’s End Farm upon their move
from Ohio to Oswego, Illinois, in 1989.
In 1971, petitioners purchased their first purebred Arabian
foal, J-Mar Elbravado. They thought J-Mar Elbravado would become
a stallion and could be bred. About 3 years after the purchase
of J-Mar Elbravado, petitioners learned that the stallion had a
cryptorchidism (recessed testicle) which rendered him useless for
breeding. Petitioners had J-Mar Elbravado gelded in 1974, but
they still continued to show him in Arabian horse shows. He was
sold in either 1977 or 1978 for an undisclosed amount.
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