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trial, Mr. Vogel, who had been to the Clayton property more than
a half of a dozen times, testified that he never saw any horses
on the upper, steeply hilled portion of the Clayton property.
Petitioner testified that he does not train horses on his
premises, nor does he give riding lessons or offer horseback
riding facilities. Access to the riding trails from the Clayton
property is obstructed by the presence of Mount Diablo; therefore
a boarding client who wants to train, ride, or exercise his or
her horse must transport the animal to another facility in the
area. Furthermore, because petitioner uses the business portion
of the Clayton premises solely for breeding and boarding horses
he needs less land for such business, than, for example, someone
who operates a horse training and horseback riding facility.
Finally, we mention in passing that the good faith of a
taxpayer is taken into account in determining whether or not
property is used by a taxpayer as his residence. Thomas v.
Commissioner, 92 T.C. 206, 243 (1989); sec. 1.1034-1(c)(3)(i),
Income Tax Regs. In assessing petitioner's credibility we note
that we were influenced by the testimony of Mr. Vogel, the
revenue agent who was called as witness for respondent. At trial
Mr. Vogel testified that petitioner's girlfriend and bookkeeper,
Patsy Lyons, spent a substantial amount of time with him
reconstructing petitioner's records. Moreover, the agent
testified that both she and the petitioner were very cooperative
and that he had "complete faith that what she was telling * * *
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