Tolbert S. Wilkinson and Suzanne T. Wilkinson - Page 5

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          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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