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petitioners did not consult experts regarding the business and
economic aspects of horse breeding and horse racing.
During 1980 through 1984, petitioners purchased 5
broodmares, 16 racehorses, and a share interest in 2 stallions.
Prior to purchasing a horse, petitioners researched the horse's
lineage and success as a racehorse, and petitioners talked to
various trainers and breeding agents. Prior to breeding their
broodmares with stallions, petitioners researched the stallions'
lineage and racing history.
Petitioners read books and periodicals pertaining to the
techniques of horse breeding and horse racing.
Generally, petitioners shared equally the ownership interest
in each of the broodmares, racehorses, and stallions, and they
shared equally the expenses and income associated with their
horse breeding and horse racing activities.
Petitioners did not own facilities in which to stable their
horses. Petitioners' broodmares and the two stallions in which
they purchased a share interest were stabled at commercial
stables in Kentucky, Maryland, and Florida. Petitioners'
racehorses were stabled at commercial stables in California.
The operators of the commercial stables were responsible for
the general care and maintenance of petitioners' horses and for
supervision of the breeding of petitioners' broodmares.
Trainers were hired for the training of petitioners' experienced
racehorses.
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