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1989 (2,313)
1990 (4,535)
1991 4,665
1992 5,458
Petitioner grew up in rural Nebraska and spent much of his
time "on the farm". He developed an interest in horses at a
young age and retained that interest into adulthood. Sometime
during the 1970's, petitioner developed an interest in "cutting
horses". Historically, a cutting horse was a horse bred and
trained to serve as a tool for separating (cutting) cattle from a
herd. Generally speaking, cutting horses are now assets that are
used by their owners to compete against other cutting horse
owners in organized "cutting" competitions for prize money.
Competitions featuring cutting horses are held at both national
and local levels, and entrants are judged on their ability to
"cut" a single steer from a herd of steers.
Petitioner began engaging in cutting horse activities in
1979. This activity has continued uninterrupted since its
commencement and has involved breeding and training horses to
compete in organized events. Petitioner entered his horse
activity without the aid of a written market study, and he has
not relied on a formal profit or business plan at any time. In
managing the affairs of his activity, petitioner used a ledger to
record various transactions and events. He also maintained a
separate "drop" file for most of his horses. The ledger and drop
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