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In 1988, following several years of poor results with regard to
the racing component of his enterprise, petitioner began
concentrating his attention on horse breeding, though horseracing
remained a peripheral part of his activity. This emphasis on
horse breeding remained petitioner's practice throughout the
years at issue.
A principal factor underlying petitioner's decision to focus
on breeding was his belief that through a combination of
successful breeding and proper training he could produce foals
that would appreciate substantially in value. In accordance with
his desire to produce quality horses with established pedigrees,
petitioner bred his horses with two of the top-rated stallions in
Maryland. Despite petitioner's efforts, however, prior to the
time of trial he had not attained significant acclaim as a
successful breeder and had not sold any foals.
Petitioner boarded his horses at a boarding facility located
approximately 20 miles from his residence. According to
petitioner, he spent several hours each morning and several hours
each night tending to his horses. In tending to his horses,
petitioner performed a variety of activities. The horses were
exercised, fed, and groomed. Medications were administered, and
stalls were cleaned. Not infrequently, petitioner's night-time
horse activity kept him at the boarding facility until midnight.
Often times, under those circumstances, petitioner slept in his
automobile at the boarding facility rather than travel the 20
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