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pony boarding program. As a longtime amateur polo player and
past president and chairman of the U.S. Polo Association,
petitioner had developed many polo contacts from all over the
world. Petitioner knew that polo players board their horses
every few months. Typically, a horse can play polo for about 3
months, and then it will need about 6 to 10 weeks to recuperate.
Many international players play polo in Florida during the winter
months and board their horses in the United States for the rest
of the year, because it is too expensive to ship the horses back
to their home countries. Petitioner believed that Bendabout was
well-suited for boarding polo ponies, because it was located
between Florida and the other States where polo is played
regularly. Bendabout has boarded up to 300 horses during the
course of a year. During the years in issue, Bendabout used
approximately 190 acres to board horses owned by third parties on
a daily fee basis. Polo players from as far away as Nigeria,
England, Argentina, and Germany boarded their horses at the farm.
For 1987, 1988, and 1989 revenues from boarding third party
horses at Bendabout were $164,365, $169,500, and $185,000,
respectively. Additional income from vanning, shoeing, and
related services generated between $25,000 and $35,000 in
revenues each year. Although the polo boarding program generated
substantial revenues during the years in issue, the activity was
hindered by severe droughts, which curtailed the farm's grazing
potential and limited the number of polo horses that could be
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