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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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