Roger G. Cotner and Marlan W. Cotner - Page 8

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               If petitioner's primary purpose in breeding Sassy was to               
          produce a foal that could be sold for a profit, we would have               
          expected that petitioners would have produced some evidence as to           
          how she intended to implement her plan, with some references to             
          projected expenses, anticipated training programs for the foal,             
          and revenue estimates that were based upon more than what she               
          paid for Sassy.  See, e.g., Hartford v. Commissioner, T.C. Memo.            
          1995-351.  As it turns out, it would appear that petitioner's               
          decision to sell Daisy was not in accordance with a previously              
          developed plan to do so, but rather resulted from the extra                 
          expenses petitioners were forced to incur in maintaining an                 
          additional horse.                                                           
               Following Daisy's birth, petitioners, who each maintained a            
          career unrelated to horse breeding, displayed little interest in            
          developing the foal so that it could be sold at a profit.                   
          Petitioner testified that a horse with Daisy's bloodlines would             
          reach a peak value between age 12 and 14, and only with extensive           
          training.  However, petitioners did not provide any training to             
          the foal between its birth in 1988 and its sale in 1990, nor did            
          they enter Daisy in any dressage competitions prior to sale.                
          Moreover, Daisy was sold at approximately 22 months old, well               
          before she could possibly reach her peak value.                             
               It is clear from the record that petitioner had a keen                 
          interest in horses in general, and dressage riding in particular.           
          It is equally clear that petitioner's interest in horses and                



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