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rider. Dressage riders are rated at different levels from
training through grand prix.
Petitioner had taken horseback riding lessons once or twice
per week for a period of 10 years prior to the year in issue.
Some of her lessons were taken from a former Olympic rider. As
of the date of trial, she had progressed to the second level of
dressage riding. There is nothing in the record that suggests
that petitioner's riding, dressage or otherwise, was done on
other than a personal, recreational basis.
At various times during her life, petitioner owned a total
of 5 horses. During 1990, petitioner owned only one horse, which
was named Sassy. Sassy was purchased in 1986 at the age of 4 for
$10,000. Petitioner acquired Sassy because of her belief that
the horse would perform well in dressage riding. Petitioner did
not acquire Sassy with the intent to breed her. It would appear
that petitioner acquired the horse solely for riding purposes.
However, shortly after she purchased Sassy, petitioner decided to
breed her. After considering several potential stallions,
sometime in the spring of 1987, petitioner decided upon a
stallion named Reckless Blade. Petitioner entered into a
standard breeding contract with the owners of Reckless Blade and
paid a stud fee of $850. In the spring of 1988, as a result of
the breeding, Sassy produced a live foal, which was given the
barn name of Daisy. The parties stipulated that petitioners
incurred actual expenses related to the breeding of Sassy and the
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