- 8 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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