5
he sold four horses between 1987 and 1992 at an average of
approximately $2,400 per horse. Petitioner's primary sources of
ponies were area dude ranches, which would periodically bring a
group of ponies to the ranch for petitioner to ride and try out.
Petitioner would then purchase the ponies he thought had
potential. Petitioner considered that it would then take as many
as 6 years to train them. To showcase the ponies for sale, he
would ride them at polo matches.
Petitioner played polo, rode and trained the polo ponies in
part, and hosted various social gatherings at the ranch.
Petitioner enjoyed training and riding the polo ponies, and on
one occasion stated that it was wonderful to get on a horse after
a long day of surgery. The social gatherings often received
publicity; petitioner considered that this type of publicity
would attract clients to the medical corporation. Petitioner was
a contributing editor of Polo magazine, which periodically
printed articles by petitioner, as well as his picture and
address.
Petitioners spent on average 3 weekends per month at the
ranch, as well as some weekday evenings. Mr. White saw to the
day-to-day affairs of the ranch, but deferred to petitioner for
any major decisions. Petitioner kept some records and paid
bills. The records shown to the Court consisted of some receipts
and canceled checks, handwritten logs kept since 1987, and typed
summaries prepared by petitioner for each year. The logs
contained one or two pages for each month, and listed
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