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1985-90
By 1985, the racehorses that petitioners had purchased in
prior years and that petitioners still owned were too old to
race. To reduce expenses and stud fees, petitioners began to
breed their broodmares only with the older racehorses that
petitioners already owned. Petitioners purchased no additional
racehorses, and petitioners moved their broodmares to California,
where their racehorses were then stabled. Thereafter,
petitioners intended to obtain racehorses only from the offspring
of broodmares and racehorses that they owned.
From 1985 through 1988, petitioners did not attempt to sell
any of their broodmares or racehorses through advertising or
auctions.
From 1985 through 1988, petitioners' broodmares produced 11
horses that petitioners trained and raced. From 1985 through
1988, these 11 horses ran in 35 races. The record does not
indicate the number of races petitioners' horses won, nor how the
horses placed.
Petitioners maintained information relating to their horse
breeding and horse racing activities on a calendar.
During 1985 through 1988, petitioners realized no income
from their horse breeding activity, and they realized total prize
money of $7,316 from their horse racing activity.
In spite of the above changes to the manner in which
petitioners operated their horse breeding and horse racing
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