Kenneth E. Perry and Mary A. Hofer - Page 6

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             believed that they could eventually generate a profit of                 
             approximately $8,000 to $10,000 per year.                                
                  Petitioners began their horse-related operation on                  
             June 28, 1986, when they acquired a registered Tennessee                 
             Walking Horse stallion from Mr. Adkins.  After purchasing                
             this stallion, petitioners acquired and developed various                
             parcels of real property to facilitate their activity.  In               
             the following discussion, we describe petitioners' real                  
             estate transactions before describing their acquisitions                 
             and transfers of horses.                                                 

             Real Estate Transactions                                                 
                  On November 21, 1986, petitioners purchased 1.72 acres              
             of real estate located in Union County, Ohio, for a total                
             price of $103,733.95.  Petitioners satisfied $11,855.24 of               
             the purchase price with cash and executed a promissory note              
             for the balance.  Petitioner obtained a portion of the cash              
             downpayment from a savings account and obtained the                      
             remainder by cashing in Mr. Perry's retirement options and               
             Ms. Hofer's stock options with General Motors.  The 1.72-                
             acre parcel included a small house which petitioners used                
             as their personal residence from the time they acquired the              
             property until 1994.  Petitioners constructed a small barn               
             and two separate paddocks on the 1.72-acre parcel.  The                  
             barn consisted of two open stalls and a separate area for                





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