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each. At the time of purchase, petitioners erroneously
believed that both mares were in foal. Petitioners later
learned that neither mare was in foal. They sold Queens
Dynasty for $75 after she became ill. They bred Spiro
Gyro, who produced a foal named Flying Footprint in 1989,
and sold Spiro Gyro in 1990 for $500. In 1991, after
determining that breeding thoroughbreds would not be
profitable, petitioners sold Flying Footprint for $1,000.
However, petitioners repossessed Flying Footprint after
receiving only $150 of the purchase price and resold the
horse to a second buyer in 1992 for $1,000.
Morgan
Sometime in 1988, petitioners purchased a registered
Morgan mare named Dancer for $300. Petitioners sold Dancer
in early 1989 for $375. The purchaser thereafter paid
petitioners to board Dancer on their property. The record
does not disclose the fee petitioners received for this
service.
Petitioners are members of the Tennessee Walking Horse
Breeders and Exhibitors Association. With the exception of
veterinary and complicated farrier services, petitioners
personally performed all of the tasks attendant to their
horse-related activity during the years in issue, including
feeding and watering, grooming, inoculations, hoof care,
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