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yearling, which is the most profitable time to sell the horse.
If the mare loses her foal, or is barren, there will be no income
for an even longer period.
During the years in issue, petitioner started a program of
acquiring brood mares and stallions for Bendabout's thoroughbred
activity. He used approximately 86 acres of the farm for this
purpose. The thoroughbred operation was concentrated in the
northwestern section of the farm and consisted of approximately
six or seven pastures, barns, and a training track. In 1987 and
1988, Bendabout generated stud fees from its stallions of $12,721
and $9,500, respectively.
From approximately 1985 through 1990, the outset of
Bendabout's thoroughbred breeding program, the farm suffered
substantial losses. Many of its brood mares aborted, had low
fertility, and lost milk. The foals of brood mares that failed
to produce milk were put on nurse mares brought in from Kentucky,
which are very expensive to lease and the foals often do not feed
as well on their milk. These problems plagued Bendabout for the
first years of it foaling program. Neither petitioner nor his
farmhands could determine the cause of the problem. In response,
Bendabout changed its operation leaving its brood mares in
Kentucky to foal after purchasing them. This was an expensive
change, however, because the farm incurred costs to board the
mares in Kentucky and then to transport them back to Tennessee.
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