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pursuing an undergraduate degree at Johns Hopkins University,
petitioner took approximately 2 years off from his studies in
order to gain the experience, skills, and knowledge necessary to
obtain a horse trainer's license. Petitioner traveled to New
York and New Jersey in order to work for horse trainers with
established reputations. Not only did petitioner need to learn
the rules and regulations promulgated by various racing
commissions; it was necessary for him to master the art of
handling a variety of horses and a multitude of equipment. It
was also necessary for petitioner to be able to properly
administer various medications and work with veterinarians.
Petitioner eventually obtained a horse trainer's license in
Maryland, Delaware, Pennsylvania, West Virginia, and New Jersey.
After graduating from Johns Hopkins University in 1977,
petitioner elected to discontinue his involvement with horses in
order to concentrate his energies on learning the art of computer
programming. In 1980, however, petitioner aspired to be a
successful racehorse owner. To this end, petitioner began a 2-
year period during which he studied racehorses. Although this
study was informal, it was regular and involved. Petitioner read
several trade periodicals and studied charts tracking the
accomplishments of various horses. Petitioner frequently used
the services and facilities of the Maryland Horse Breeders
Association to conduct research and study pedigrees. Petitioner
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