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demonstrates that petitioner’s involvement in the equestrian
world is the cornerstone of her cultivation of relationships with
her clientele. Given the nature of petitioner’s clientele, we
find her testimony about the relationship between her equestrian-
related activities and her design business to be credible and
logical.
Respondent argues that petitioner did not start riding
horses for the purpose of promoting her interior design business,
citing the fact that petitioner had competed for sport since a
young age. We recognize that petitioner’s interest in horses and
participation in competition preceded the formation of her
equestrian-based design activity. Petitioner’s business plan as
executed abruptly converted her preexisting hobby into part of an
integrated business venture after her divorce.
Respondent also relies on the existence of the L.L.C.
entitled “Topping White Design” to argue that petitioner’s design
business was separate from her equestrian activities. Respondent
argues that petitioner should be held to the form of her
structure, citing the fact that petitioner used the name of
Topping White in dealing with third parties. However, there is
no basis to restrict petitioner’s overall activities to Topping
White. Petitioner deals with clients and is known in the
equestrian world as “Tracy Topping”. Petitioner conducts both
aspects of her business through Topping White, using the same
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Last modified: November 10, 2007