1989, meeting of APECO's board, the concept of a "turbo airless
sprayer" was discussed, but such a product was not mentioned in
the minutes of subsequent board meetings on November 20, 1989,
and January 16, 1990. Eventually, the sprayer developed from the
concept came to be known as the "Planatronic". During mid-1989,
APECO's personnel had not allocated a specific amount of money to
the development of the Planatronic. APECO experienced continuing
difficulties in developing the Planatronic into a reliable
product that were not solved as late as July 1991.
Mr. Kluener owned 41 thoroughbred horses, and he had at one
time owned as many as 120 to 125 such horses. His horse-related
activities were conducted through a sole proprietorship known as
Robert G. Kluener Enterprises, which maintained an office in
Cincinnati. Mr. Kluener's assistant worked in that office and
was responsible for a variety of administrative tasks relating to
his personal and business activities, including the paperwork and
check-writing connected with the horse-related activities.
As a result of the collapse of the real estate ventures, his
obligations to Fifth Third, and the need to fund APECO, Mr.
Kluener could no longer afford the losses generated by the horse-
related activities, which, for the first 7 months of 1989,
amounted to approximately $400,000. Moreover, due to declining
health, Mr. Kluener did not enjoy those activities as much as he
formerly had enjoyed them, and he began to lose interest in them.
Accordingly, Mr. Kluener decided to sell his horses. His tax
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